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Do structures on land preclude it from being treated as undeveloped for VAT exemption purposes?
Supreme Administrative Court draws attention to the economic nature of land sale transactions The Supreme Administrative Court (NSA), in a ruling of 23 August 2024 (ref. I FSK 1670/20), again addressed the issue of the application of the VAT exemption to the sale of undeveloped land....
Transfer pricing documentation obligations for 2023: deadlines are looming
Transfer Pricing: obligations await! The holidays are coming to an end, and as children head back to school, businesses must also turn their attention to fulfilling transfer pricing obligations for the 2023 tax year. Key deadlines are approaching for: Local transfer pricing documentation...
Employer's liability for VAT on empty invoices issued by an employee - NSA judgment of 3 September 2024 (ref. I FSK 1212/18)
Employer’s liability for VAT on empty invoices issued by an employee – NSA judgment of 3 September 2024 (ref. I FSK 1212/18) Last Tuesday (i.e. 3 September 2024), the Supreme Administrative Court [hereinafter: NSA or the Court] issued a judgment (I FSK 1212/18) in a case...
Call-off stock procedure
What is the call-off stock procedure and what is its application? In Intra-Community trade, as a rule, the movement of goods by a taxpayer constitutes an Intra-Community acquisition of goods. This means that the taxpayer carrying out such a movement is required to register for VAT...
Improved proposal of changes to property tax
Improved proposal of changes to property tax On September 3, 2024, the Ministry of Finance presented a new draft of changes to property tax, which are to apply from 2025. The previous draft was the subject of a consultation conference, which was also attended by representatives of...
11 individual recognitions in ITR World Tax Leaders 2025 ranking
11 individual recognitions in ITR World Tax Leaders 2025 ranking We are happy to announce that as many as 11 our experts have been listed in this year’s ITR World Tax Leaders ranking! This is another year in a row when we have the largest number of distinguished experts among...
“JPK CIT” reporting from 2025 - a new obligation for all taxpayers
“JPK CIT” reporting from 2025 – a new obligation for all taxpayers On August 16, 2024, the Minister of Finance signed a regulation regarding the details of JPK CIT reporting. It is to be formally published in the near future. JPK CIT is a new obligation regarding the transfer...
Sixth method - valuation techniques in transfer pricing
Transfer prices can impact the amount of income taxed in different countries. To ensure compliance, set these prices at the same level that unrelated parties would use in their transactions. Here’s how to do it. Various transfer pricing verification methods are used to assess...
Doing Business in Poland
Doing Business in Poland What do you need to be aware of in terms of legal, tax and accounting when setting up and running a business in Poland? Due to economic and business conditions, Poland is an attractive country for business, which attracts many foreign investors. However,...
Termination fee can be a tax deductible cost if it allows taxpayer to increase profits
On July 25, 2024, the Director of the National Tax Information issued an individual tax ruling[1] confirming the right to recognize a fee for the termination of a real estate sales contract as a tax deductible cost. What was the case about? In the case under review, a real estate...
MDDP in Tier 1 in ITR World Tax 2025 ranking
MDDP in Tier 1 in ITR’s World Tax 2025 ranking 🏆 We are delighted to announce that in the latest edition of the prestigious World Tax 2025 ranking prepared by International Tax Review, MDDP maintained its positions in two categories – Indirect Tax and General Corporate...
Benefit test: a global priority for tax authorities in transfer pricing
What is a benefit test? The benefit test is an analysis that confirms the following: the purchased intangible services have indeed been performed, the recipient derives benefits from the purchase that contribute to their income, the purchase of services is business rational. Who...
Do you hold a permanent residence permit? This could deprive you of return relief
The current position of the tax authorities confirms that people immigrating to Poland permanently who do not have a Pole’s Card on the date of their move – either because they have not applied for it before or have already obtained a permanent residence permit –...
Intra-group funding: financial transactions are under scrutiny
Authorities around the world are increasingly scrutinizing the nature of intra-group loans We observe that tax authorities and courts are more frequently recharacterizing loan transactions, challenging their substance and arm’s length nature. Authorities are now examining not...
Operator to help settle VAT on deposit refund system (DRS)
At the end of July, a further version of the draft amendment to the DRS legislation also addressed tax issues. Although it takes into account a significant part of the postulates made by future participants of the system, the solutions proposed in it as to the settlement of VAT in...