Not every adjustment to transaction prices is a transfer pricing adjustment Related parties often apply transaction price adjustments in their settlements. The so-called contractual adjustment and transfer pricing adjustment within the meaning of Article 11e of the CIT Act are perceived...

New tool for electronic communication with tax authorities – the e-Tax Office On 7 July 2022, the Act amending certain acts in order to automate the handling of issues by the National Revenue Administration (KAS) is to come into force. The new regulations are intended to automate...

In recent days, Artur Soboń – Deputy Minister of Finance – announced changes in CIT aimed at simplifications and solutions aligned with the current economic situation. The Ministry of Finance proposes simplified rules concerning the documentation of tax haven transactions and increasing...

Polish Deal [Polski Ład] 2.0 – changes in PIT, ZUS social security insurance and NFZ National Healhcare Funds as of 1st July 2022 Amended provisions of the so-called “Polish Deal” have been published in the Journal of Laws. Some of the changes enter into force already on 1st...

MDDP on Polish Taxes I VAT Groups June 22, 2022 at 10:00 a.m.June 22, 2022 | 10:00 a.m.: Register In 2023, VAT taxpayers (and branches of foreign taxpayers) will have the opportunity to form a VAT Group, allowing a group of entities to be treated as a single VAT taxpayer. As a result,...

Today we wish to remind you of how important it is to properly determine the functional profile for TP purposes. The functional profile results from the entity’s involvement in the transaction: the functions performed, the assets involved and the level of risk exposure. Importantly,...

MDDP on Polish Taxes I Tax on shifted income, including financing costs and taxation of hidden dividends June 8, 2022 at 10:00 a.m. Polish legislator often uses the carrot and stick approach. However, when it comes to financing costs, stick policy prevails. Each and every year, new...

Poland: Last call for taxpayers in Poland to review ATAD 2 Poland has implemented European Council Anti-Tax Avoidance Directive (ATAD 2) by introducing anti-hybrid provisions into its domestic law. The provisions apply starting from January 2021 and the taxpayers should take them...

MDDP is the Content Partner of the Polish Real Estate Forum in Sopot This year’s Polish Real Estate Market Forum in Sopot will be held under the title “Still on the wave or are we already drifting? The real estate industry facing constant challenges”. How...

MDDP is a partner of the IFA conference on ATAD 3 According to ATAD3, high risk companies (the reporting undertaking), that may become shell companies, are those that derive more than 75 percent of their revenue from interest, royalties,  dividends, and financial income;...

The lifting of the state of epidemic in Poland and taxes By the regulation of the Minister of Health published in the Journal of Law, the state of epidemic in Poland is cancelled. At the same time, the other published regulation of Ministry of Health introduced in...

MDDP on Polish Taxes I New Polish CIT exemption for foreign investors – so-called Estonian corporate income tax June 1, 2022 at 10:00 a.m. Starting from 2021, there is a new tax relief – so called the Estonian CIT – in Polish tax law. The relief allows to defer payment of CIT for...

MDDP on Polish Taxes I Tax allowances and exemptions May 25, 2022 at 10:00 a.m. In 2022 new and refreshed CIT incentives were introduced. Nowadays taxpayers can benefit from different deductions while developing their business, starting from the concept through test production ending...

Income tax on buildings returns from June 2022 By the announcement of the Minister of Health, from May 16, 2022, the state of epidemic in Poland is cancelled and the state of epidemic threat is introduced. This change means that the suspension of the income tax on buildings,...

Changes in the scope of corporate income tax, which entered into force on January 1, 2022, have an impact on the tax aspects of financing investments.