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CBAM – detailed reporting obligations and new guidance from the European Commission
On 17th August, the European Commission published rules governing the implementation of the CBAM mechanism during its transitional phase. The transitional phase starts already on October 1, 2023 and will last until the end of 2025. During this period, importers will be required to...
The key role of benchmarking in safeguarding a taxpayer
The primary purpose of a benchmarking analysis is to establish and verify that the terms and conditions in transactions between related parties correspond to the arm’s length principle. Although only one of the integral elements of transfer pricing documentation, these analyses are...
Cooperation with influencers through barter
Marketing contracts are an area where, in addition to the legal risks, particular attention should be drawn to the correct wording of tax provisions and tax consequences of the activities described therein. For instance, the supply of products to an influencer in exchange for promotional...
MDDP experts in ITR World Tax Leaders 2024
MDDP experts in ITR World Tax Leaders 2024 As many as 12 MDDP experts have been listed in the ITR World Tax Leader ranking. This means that again MDDP has the LARGEST number of distinguished experts among all companies in Poland! MDDP experts are distinguished in 5 key categories:...
MDDP advised Griffin Capital Partners and Redefine Properties on the acquisition of Stokado
MDDP advised Griffin Capital Partners and Redefine Properties on the acquisition of Stokado MDDP has advised Griffin Capital Partners, a Polish investor and a private equity and real estate asset management firm, and Redefine Properties, a South African investor, on the acquisition...
Personal affiliations - excluding documentary exemption for Treasury-affiliated companies
Identifying the links between the parties to a transaction is one of the first and at the same time the most important steps in the process of identifying transfer pricing obligations. Correct determination of linkages is particularly important if the parties to the transaction wish...
Deposit Refund System: A Revolution for Now
Deposit Refund System – a revolution for now The introduction of a deposit refund system in Poland is a huge financial and logistical challenge that awaits entrepreneurs in the coming years. What will change? The deposit refund system is a way to collect used beverage packaging...
MDDP recognized in World Tax and World TP 2024 rankings
MDDP recognized in World Tax and World TP 2024 rankings With great pleasure, we announce that in the latest edition of the prestigious World Tax and World TP 2024 rankings prepared by the International Tax Review, MDDP has maintained its positions in all four categories! 🏆 Tier 1...
How to manage financial transactions – TP aspects in Poland
How to manage financial transactions – TP aspects in Poland In the current economic situation, the importance of intragroup financial transactions has been growing. Companies are increasingly borrowing from a related party instead of financing from an external financial institution....
How to manage financial transactions – transfer pricing aspects in Poland
The economic situation in the global markets as well as the increase of banking reference rates, higher inflation rate could influence the conditions of intragroup financial transactions.
MDDP advised Cornerstone on the acquisition of the Warta Tower
MDDP advised Cornerstone on the acquisition of the Warta Tower The experts from MDDP Michalik Dłuska Dziedzic and Partners advised a company belonging to the investment platform Cornerstone Investment Management on the acquisition of the Warsaw office building Warta Tower, located...
VAT classification of sales of commercial real estate as the Organised Part of an Enterprise
Judgment of the Supreme Administrative Court of 28 July 2023 (ref. I FSK 892/18) The recently announced judgment of the Supreme Administrative Court reopens the formerly hot-bottom issue of VAT taxation on the sales of commercial real estate. The essence of the dispute is the classification...
Setting up a consortium and transfer pricing obligations
A consortium is a collaboration of at least two businesses to achieve a predetermined goal or to carry out a specific project for mutual benefits.
Repeal of the state of epidemic emergency - impact on transfer pricing obligations
Repeal of the state of epidemic emergency – impact on transfer pricing obligations Since the lifting of the state of emergency in Poland, many regulations and procedures related to transfer pricing have taken on a new dimension. In a previous alert dated 20 June, our experts...
Risk of losing PGK status for non-arm’s length transfer prices
Remuneration in transactions between related parties should be determined on an arm's-length basis: on such terms as third parties would determine between themselves. Otherwise, in the event of an audit, their arm’s length nature is expected to be challenged.