The condition of beneficial ownership has remained one of the key issues in withholding tax for many years, particularly in the context of applying exemptions provided for in the CIT Act. The legislator explicitly made the exemption from withholding tax on royalties and interest conditional...

Groundbreaking CJEU judgment in the first Polish tax case – VAT deduction independent of possessing an invoice. Change in Polish tax practice.

Personal links and the TP documentation exemption – when Article 11n(5) of the CIT Act applies and what risks arise from KIS practice and court case law.

Changes to the taxation of business activities and the selection of cash-based PIT in 2026 – key dates The deadline for deciding on the taxation of business income for 2026, including the option of cash PIT, is approaching. Methods of taxing income (revenue) from business activities In...

MDDP advised on the acquisition of the iconic Senator office building and PZO complex in Warsaw MDDP provided tax support on two significant transactions in Warsaw’s office market: the acquisition of the Senator office building in the city centre and the PZO complex in Praga. In the...

Companies with a shifted financial year – check your transfer pricing obligations. TP audit, documentation, TPR, and Master File, including for foreign entities.

We are returning to you with the latest information on the reform of the National Labour Inspectorate (PIP). On 30 January this year, a new version of the draft law extending the powers of the PIP was published on the website of the Government Legislation Centre. According to...

The deadline for CBC-P for 2025 is 31 March 2026; check who is required to file, what data must be reported, and the applicable sanctions.

A set of machines forming a robot also covered by the robotisation tax relief – the Voivodeship Administrative Court in Warsaw breaks with prior case law   In its judgment of 21 January 2026 (case no. III SA/Wa 2178/25), the Voivodeship Administrative Court (VSA) in Warsaw confirmed...

Planned changes to transfer pricing regulations – initial announcements   The legislative agenda includes planned amendments to the PIT and CIT Acts, expected to significantly impact transfer pricing. The draft bill is in the planning phase and is expected to be published in Q1–Q2...

WHT – check if you need to send a follow-up WH-OSC tax return   The deadline (February 2, 2026) is approaching!   Summary WH-OSC for 2025 If, in 2025, you, as a tax remitter send a WH-OSC  regarding a taxpayer, and then made so called “further payments” (dividends, licensing...

Transfer pricing adjustments as a tool for restoring arm’s length conditions. Legal requirements, tax risks, VAT implications and Polish practice.

Polish tax in 2026 digital tax compliance becomes business reality The beginning of 2026 did not bring a single, comprehensive tax reform in Poland. Instead, the turn of the year heralded several tax adjustments, while some key measures will become effective over the coming months....

Eligible costs under the research and development (R&D) tax relief include, among others, expenses incurred on the remuneration of employees performing R&D activities. These expenses may be deducted to the extent that the time devoted to R&D activities remains in proportion...

Transfer pricing adjustments in Poland and abroad. The arm's length principle, OECD guidelines, tax conditions, case law, and the risk of double taxation.