Taxpayers may apply to start cooperation with the National Revenue Administration [NRA] based on the so-called Cooperative Compliance Programme, a pilot formula assuming mutual trust, understanding and transparency. This is a new quality of the taxpayer’s relationship with...

On 19 May 2024, Directive 2024/1226 entered into force, which introduces significant changes to the application and enforcement of EU sanctions imposed in connection with Russia’s aggression against Ukraine. Until now, EU Member States had full discretion in determining penalties...

How well do you know MDDP’s Transfer Pricing Team? Did you know that this year we are celebrating the 20th anniversary of both MDDP and our Transfer Pricing Team? Over the years, we have built extensive experience and international expertise, which have brought us to where we...

Tax aspects of redevelopment in the real-estate industry   A lack of investment plots in prime locations means that developers are increasingly interested in purchasing developed properties such as old office buildings, commercial or industrial facilities either to demolish or modernise...

Ministry of Finance general ruling: RES projects and asbestos removal in local government units  outside VAT, but also without retroactive adjustment of settlements Following the judgments of the Court of Justice of the EU last year concerning municipal projects involving the installation...

Charging an electric vehicle at a network of charging points to which the user has access on the basis of a subscription contracted with a company other than the operator of the charging point means that the electricity consumed is supplied to users by that operator and the company...

When distinguishing between single-purpose vouchers (so-called SPVs) and multi-purpose vouchers (so-called MPVs), it is necessary to examine whether, at the time of issue, the place of supply of the transaction to the final consumers to which the voucher relates and the amount of...

Financial transactions are one of the most common transactions between related parties and also most frequently controlled by the tax authorities. Due to the an extensive catalogue of financial transactions and their level of complexity, taxpayers often face problems in justifying...

Judgment of the Voivodship Administrative Court in Warsaw of April 18, 2024, ref. III SA/Wa 8/24 It would seem that the topic of the importance of the acceptance protocol for determining the moment when VAT liability arises for the provision of a service is quite clear and straightforward,...

With each passing year, courts increasingly confirm that a properly prepared benchmarking study can be an extremely important tool, both for taxpayers and tax authorities. Tax authorities often challenge benchmarking study by either conducting new analyses or modifying those presented...

 KSeF postponed until 2026 We already know the new date for the mandatory KSeF to come into force: it is the first quarter of 2026; interestingly, contrary to earlier announcements by representatives of the MF, a ‘phasing in’ of the project is assumed: – from...

New obligation in the Accounting Act Large multinational entities based and operating in Poland will be obliged to publish reports related to income tax paid in the countries in which they operate. The purpose of the amendment to the Accounting Act, which sets out the rules for the...

Following the meeting of the VAT EXPERT GROUP in Brussels on 18 March, the next steps for VAT in the digital age are becoming much clearer. The group, made up of specialised VAT experts, plays a key role in providing information and opinions on the practicalities of implementing EU...

Today, we present the fourth and final entry in our series on transfer pricing. From previous posts, you already know what transfer pricing is (and certainly what it isn’t), who related parties are, and how to assess whether the prices applied in an intragroup transaction are...

Price adjustments are still not a clear-cut issue and raise questions for taxpayers. In 2023, administrative courts issued rulings on adjustments in three main areas described below. Definition of transfer pricing adjustments It is worth recalling that TP adjustments refer to transactions...