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...

Intangible services have long been a focus of tax authorities. It is therefore essential to understand the key risk areas associated with these service costs and to manage them proactively throughout the year—not just when preparing transfer pricing documentation. Confirmation of...

Companies are increasingly investing in sustainable development. Green innovations not only help protect the environment but also bring tangible business benefits. One of the tools supporting companies in this transformation is the Research and Development (R&D) tax relief, which...

Revolutionary judgment by the CJEU on provisions on joint and several liability of management board members The Court of Justice of the European Union (CJEU) today issued a landmark judgment (Case C-277/24 Adjak) challenging the model adopted in Poland of joint and several liability...

MDDP begins cooperation with the ALL network – Alianza Legal de Firmas de Abogados We have been starting a new chapter of international strategic cooperation with the ALL network (Alianza Legal de Firmas de Abogados). Thanks to this cooperation, MDDP will strengthen its position...

The digital reform of the VAT system in the European Union is inevitable. A package of changes to the EU VAT directive called “VAT in Digital Age” (ViDA) has been adopted by the European Parliament at its meeting on February 12th this year. This is the next stage in the...

The approaching deadline for PIT settlements for 2024 poses a serious challenge for many taxpayers regarding how to correctly settle their income, especially foreign income when it comes from investments through foreign banks. This topic becomes particularly important for people who...

The obligation to integrate payment terminals with cash registers is repealed and other VAT changes from April 1, 2025 We present the most important changes in VAT and cash registers regulations introduced by the Act of January 24, 2025, amending the Act on Value Added Tax, the Act...