What are financial transactions in the context of transfer pricing? Financial transactions encompass a wide range of intercompany activities, including loans, credit facilities, financial guarantees, bond issues, and other financial instruments. These are among the most common categories...

Forum for Ecological Solutions in Real Estate (FERN) 2025 In response to the evolving needs of the real estate market, a unique conference – “Forum for Ecological Solutions in Real Estate 2025” (FERN) – will take place on April 7. This event presents an excellent opportunity...

One of the controversial issues among taxpayers and tax authorities is the requirement for foreign company branches operating in Poland to obtain a separate NIP (Tax Identification Number). Tax authorities emphasize in their interpretations that a branch, as a payer of income tax...

Share-based incentives in Poland: benefits and key considerations In today’s competitive job market employers are increasingly implementing additional benefits to attract and retain key employees. Among these, incentive schemes that grant employees company shares have gained significant...

An increasing number of companies are incorporating ESG (Environmental, Social, and Governance) factors into their business strategies. One of the key challenges in this process is tax risk, which can impact not only financial stability but also reputation and stakeholder relationships....

From the beginning of 2022, a provision limiting the amount of depreciation allowances made by real estate companies was introduced into the CIT Act. It allows depreciation write-offs on buildings and premises (group 1 of the NIT) to be recognised as tax deductible costs, but only...

The tax on shifted income was intended to protect the Polish tax base from transfers income to tax havens. Initially, the regulations covered both domestic and cross-border payments, but after one year of being in force, the scope of the tax was limited to payments to non-residents...

CJEU extends Polish CIT exemption to self-managed investment funds On February 27, 2025 the CJEU delivered a pivotal judgement in a Polish case, stipulating that the requirement for external management constitutes a breach of EU law. The case concerned self-managed investment funds,...

For years, financial, service, and distribution or production transactions have consistently been the most commonly reported in the TPR form. This is largely because they are easy to identify as subject to transfer pricing regulations. However, in a complex and rapidly evolving business...

The Head of the National Revenue Administration [KAS] has refused to issue letter of practice regarding incentive programs (ref. DKP16.8082.4.2024 and DKP16.8082.7.2024). This decision raises questions about the tax security of such solutions and potential risks for companies implementing...

The export of goods is subject to a 0% VAT rate, provided that the taxpayer possesses a document that the goods have been dispatched outside the territory of the European Union prior to the deadline for filing the VAT return for the relevant accounting period. According to the VAT...

Landmark judgement of the CJEU reshapes Polish tax exemption for investment funds The Court of Justice of the European Union (CJEU) issued a judgement (Case C-18/23) on February 27, 2025, declaring that Polish requirements limiting CIT exemption to externally managed funds are in...

The European Union faces the challenge of reconciling ambitious climate goals with the need to enhance business competitiveness. The Omnibus Package, announced on February 26, 2025, aims to address these needs. The new regulations seek to simplify sustainability-related legislation...

Chain transactions create plenty of difficulties for taxpayers in terms of determining their VAT implications. Currently, intra-Community transactions are less problematic, due to the regulation of these questions as part of the package of “quick fixes” changes introduced in 2020....

As a rule, the income of non-resident taxpayers in Poland, in the case of management or mandate contracts, is in most cases subject to 20% flat-rate income tax. However, it is worth remembering that in certain cases foreigners may settle according to the tax scale, i.e. according...