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ViDA package published - should we be afraid of the EU "schema"?
ViDA package published – announced DRR dates unchanged On 25 March 2025, the VAT in the Digital Age (ViDA) package was officially published in the Official Journal of the European Union as Council Directive (EU) 2025/516. This is the legislative final of a long-awaited reform...
Preliminary adjustment in estonian CIT – lump-sum tax on company income
The estonian CIT, or lump-sum tax on company income, is a form of taxation that allows the postponement of tax payment until the actual distribution of profits to an individual – a shareholder. A key element in the initial phase of applying this taxation model is the calculation of...
A new approach of the tax authorities to debt financing costs in RES – how can you benefit?
The renewable energy sector is growing rapidly, yet investors often face unfavourable tax regulations and a strict approach of the tax authorities.One of the major challenges has been the limited possibility of including debt financing expenses (e.g. loan interest) as tax deductible...
Transfer pricing adjustments – how to mitigate the risk of challenges?
As the financial year-end approaches—bringing tax closures and financial audits—it’s the last chance to thoroughly review settlements, pricing, and contractual terms and make any necessary adjustments. Taxpayers often ask: What are transfer pricing (TP) adjustments? Why are TP adjustments...
Tax residence and personal income tax settlements
The status of tax residence in Poland is crucial for the correct settlement of personal income tax. Polish tax residents are obliged to settle income tax in Poland on their total income, both domestic and foreign (unlimited tax liability). Polish non-residents for tax purposes, on...
Company established through conversion of sole proprietorship is a taxpayer starting business
A capital company formed by the conversion of a sole proprietorship is considered as a taxpayer starting a business. On March 11, 2025, the Supreme Administrative Court issued a ruling (referenceII FSK 1412/24) that may significantly impact taxpayers arising from the transformation...
GloBE: Agreement on the DAC9 Directive
The Council of the European Union – in a press release dated March 11, 2025 – announced that a political agreement had been reached on the amendment of the directive on administrative cooperation (under the so-called amending directive, referred to as DAC9). The amendment aims to...
CJEU issues revolutionary ruling on board members’ joint and several liability
CJEU issues revolutionary ruling on board members’ joint and several liability On February 27th 2025 the Court of Justice of the European Union issued a landmark judgement that challenges the model of joint and several liability of the management board members. The ruling in case...
Tomasz Michalik again honoured in Chambers Europe ranking
Tomasz Michalik again honoured in Chambers Europe ranking! We are delighted to share great news – once again Tomasz Michalik has been awarded a prestigious distinction in the most recent edition of the Chambers Europe ranking. For the 19th time in a row, Tomasz has been placed...
Withholding tax and the concept of industrial equipment – unfavorable position of the SAC
Both the provisions of the Corporate Income Tax (CIT) Act and the provisions of various double taxation treaties provide for the obligation to withhold tax on payments made to non-residents for the use of so-called “industrial equipment.” In principle, non-residents earning...
Transactionally significant judgment on the redemption of shares
A Transactionally significant judgment on the redemption of shares The combined efforts of MDDP’s Real Estate and Tax Litigation teams have successfully concluded proceedings regarding the redemption of shares, specifically concerning the abuse of law clause for one of our clients....
Tax on income from buildings. Settlement, doubts, refund applications
What is the tax on income from buildings? The tax on income from buildings has been in effect in Polish law since January 1, 2018. This tax, commonly referred to as the “minimum tax on buildings,” is a solution designed to ensure effective taxation of entities operating...
The right to a VAT refund from the tax office when it cannot be recovered from the supplier – another judgment of the CJEU
Does the tax authority have the right to deny the taxpayer the right to deduct input VAT from a transaction that, in its opinion, was not subject to taxation at all? At first glance, it seems obvious that it does – after all, the supplier can correct the invoice in such a scenario,...
KSeF - it is high time to prepare!
KSeF – it is high time to prepare! April 2, 2025 at 14:00 CET Register The implementation of KSeF is a major challenge, but also an opportunity to bring order and innovation to companies. The process itself, depending on the size of the organisation, can take from a few to even...
PIT settlements: Solidarity Levy and Tax Losses
According to the current position of tax authorities and administrative courts, the tax base for the solidarity levy can be reduced by tax losses from previous years. However, it should be noted that the deduction of tax losses is only possible within the same source of income.  ...