Does a free of charge surety granted to a taxpayer subject to Estonian CIT give rise to a tax obligation to recognise income as hidden profits or revenue from free of charge benefits? The conclusions of the latest individual tax ruling[1] indicate that it does not.   Hidden profit...

Recent discussions have focused on the EU institutions’ evolving stance on ESG (Environmental, Social and Governance) reporting. A central element of these changes is the so-called Omnibus Package, which introduces substantial amendments to both existing and forthcoming regulations—particularly...

The issue of intra-group transactions in the context of value-added tax (VAT) is increasingly attracting the attention of the Court of Justice of the European Union (CJEU). Recent cases underscore the importance of delineating the boundaries between direct tax (CIT) and indirect tax...

The Offline24 mode – as explicitly described by the Ministry of Finance – is considered the most significant enhancement introduced to support entrepreneurs in implementing the National e-Invoicing System (KSeF). But is it truly a facilitation, or rather a trap resulting from not...

Can the payment of remuneration for the redemption of shares, financed from profits earned before the implementation of Estonian CIT, result in lump-sum taxation of company income? Although it may appear that profits once subject to taxation should not be subject to further taxation,...

Cryptocurrencies are becoming an increasingly common means of settlement, including in financial transactions – such as lending or collateral. It is worth taking a look at what tax implications are associated with the use of cryptocurrencies in such situations. Lending in traditional...

Recently issued individual interpretations indicate that tax authorities have inconsistent positions on the classification of lease or rental costs from related entities as so-called hidden profits. While the regulations remain consistent, the authorities’ positions are subject...

The Organisation for Economic Co-operation and Development (OECD) plays a pivotal role in shaping the global tax landscape, particularly in the context of the digital economy. Its objective is to establish a more equitable and predictable international tax framework that addresses...

In its judgment in the Polish case of 8th May 2025, ref. C 615/23, the CJEU confirmed that lump-sum compensation paid by local government units to public transport operators, aimed at covering losses from this business activity, is not subject to VAT. The judgment confirms the previous...

Modern companies operating in international markets face the challenge of aligning customs and transfer pricing policies. A lack of consistency between these areas can lead to significant tax, operational and financial risks. For this reason, close cooperation between customs and...

With the launch of the first deposit return systems in October 2025, new rules will come into force for beverage containers included in the system and marked with the “DEPOSIT” on a label. However, many beverage containers will remain on the market—either temporarily or...

On 30 April 2025, the Court of Justice of the European Union (CJEU) delivered another important judgment in Case C-278/24 (Genzyński) concerning the compatibility with EU law of the Polish rules on the joint and several liability of board members for company tax arrears. The CJEU...

MDDP at the Withholding Tax Conference We are pleased to announce that Justyna Bauta-Szostak, Partner, Tax Advisor, and Legal Counsel at MDDP, will participate in the 1st Nicolai Copernici Global Tax Talks: Withholding Tax Challenges conference. This prestigious event will take place...

Exemption from WHT without recognising the recipient as the beneficial owner The Supreme Administrative Court (NSA) ruling concerning one of the most problematic issues in the area of withholding tax (WHT), confirming that, in order to apply the WHT exemption, it is not always necessary...

Successful defence of the right to input VAT deduction Case concerning the right to the input VAT deduction on complex supplies related to the major project involving the production and outfitting of innovative modular buildings. The tax authority denied the company the right to deduct...