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...

CRS/Euro-FATCA reporting for 2023 will also include reportable accounts held by persons from Georgia and Ukraine On 28 March 2024, the notice of the Minister of Finance of 22 March 2024 on the list of countries and territories covered by the CRS reporting obligation for 2023 was published...

Applying the parent–subsidiary exemption in Poland is becoming more difficult Monika Dziedzic and Łukasz Kumkowski consider the dividend taxation exemption for payments made by Polish companies and explain the fulfilment of the beneficial ownership requirement by foreign holding companies...

The fundamental rule in transfer pricing is the arm’s length principle. When applied correctly, it ensures that related parties conduct transactions under terms that are consistent with those which would be agreed between independent parties. But how do we know that the conditions...

Intra-group loan Intra-group loans, like other related party transactions, should be made on an arm’s length basis. In order to verify loan transactions to comply with the arm’s length principle, the comparable uncontrolled price method is most often used in the external...

9 awards for MDDP in Rzeczpospolita ranking We are pleased to share information about MDDP’s achievement in the latest Rzeczpospolita Ranking of Tax Advisory Firms MDDP experts as leaders in the CIT, PIT and VAT categories As many as three MDDP experts made it to the podium...

The world of VAT is a dynamic one in which change is the only constant. New settlement rules, the National e-Invoicing System (KSeF), the European Commission’s planned regulations resulting from the VAT in the Digital Age project, changes resulting from CJEU case law and Polish...

The world of VAT is a dynamic area in which change is the only constant. New settlement rules, the National e-Invoice System, the European Commission’s planned constructions resulting from the VAT in the Digital Age project, changes in practice resulting from the CJEU case law...

Have you heard of the “six degrees of separation” theory? It’s a concept that assumes that, as a resident of Earth, you can meet any other person in the world with just six or fewer mutual connections between you and that person, whether through acquaintances, friends, or their...