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! 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...

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.   Solidarity...

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...