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...

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...

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...

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...

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 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! 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...

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...

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....

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...

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...

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...