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...

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 To...

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...

In the dynamic business world, planning of settlement between related parties is becoming an essential part of groups’ business strategy. Changes in the market affect the development of new technologies, products and services. They determine the activities of companies in achieving...

One thing is certain: there is no turning back from National e-Invoice System [hereinafter: KSeF]. This was confirmed by the Minister of Finance, Andrzej Domanski, on 21 March 2024 at a meeting where representatives of the ministry summarised the consultation cycle on KSeF and outlined...

Happy Easter! The Easter holidays are approaching;   on this occasion we wish to our clients, business partners, friends, employees and their families   confidence in a peaceful and secure future many special moments spent with loved ones and reflect on what is truly important.   Let...

Judgment of the Provincial Administrative Court (WSA) in Warsaw of 21 February 2024, ref. no. III SA/Wa 2083/23. Recently, the Polish energy sector has witnessed an unusual phenomenon: the emergence of negative electricity and gas prices on the market. This situation has given rise...

The MDDP team was responsible for achieving an important ruling by the Supreme Administrative Court on the VAT bad debt relief. The dispute concerned whether it was possible to take advantage of the VAT bad debt relief despite the expiry of the deadline provided for in the legislation,...

The MDDP team was responsible for leading the case to a landmark ruling by the Supreme Administrative Court on financing costs in full factoring. The issue in dispute in the case was whether the costs of factoring proper (full factoring) are subject to the limitations on inclusion...

The MDDP team was responsible for leading the case to a landmark ruling by the Supreme Administrative Court on the conditions for the application of the 0% excise duty rate. The dispute concerned whether the requirement to issue an e-DD must always be met in order to apply the zero...