In the judgment of 4 May 2023 in Case C-127/22 ‘Balgarska telekomunikatsionna kompania’ EAD [hereinafter: Company] v Direktor na Direktsia ‘Obzhalvane i danachno-osiguritelna praktika’ – Sofia [hereinafter: tax authority], the CJEU ruled on the obligations...

Doubts over TP statement dispelled! No possibility to submit a TP statement – announcement The Ministry of Finance has indicated in today’s announcement that until the new versions of the TPR-C and TPR-P forms are published, the applicable template for the TPR Information filed...

Resuming reporting of domestic tax schemes During the May holidays on May 2, 2023, the Ministry of Health published a draft regulation according to which the state of epidemic threat will be cancelled on July 1 of this year. From this day on, the suspension of deadlines for reporting...

Magdalena Marciniak and Marta Klepacz of MDDP lay out the challenges and complexities of attempting group analysis in Poland, and outline the approach of the domestic tax authorities. Benchmarking studies are a well-known topic in most tax jurisdictions. Just like anything else in...

An increasing number of countries are introducing safe harbour mechanisms. This is a significant convenience for taxpayers in settlements with related parties. Among the world’s largest economies, these regulations are in place in the US, India, South Korea, Russia, Australia, Spain,...

A new regulation in Poland explained: family foundations and their taxation The purpose of a family foundation, which is a new structure for Poland, is to accumulate wealth and manage it in the interest of the beneficiaries. As a rule, a foundation is exempt from corporate income...

The European Parliament and the EU Council have approved the draft regulation on the CBAM (Carbon Border Adjustment Mechanism), the issue that have popped out on our blog several times. Pursuant to this draft, the first obligations related to CBAM will apply from 1 October 2023. CBAM...

It is a truth commonly acknowledged that related-party settlements have been scrutinized by tax authorities for several years. In 2022, more than 500 transfer pricing controls were taking place: 370 were completed and 242 were pending. In 2022 alone, the amount of additionally estimated...

Justyna Bauta-Szostak and Bartosz Głowacki of MDDP report on the introduction of family foundations in Poland, and how they will be taxed. On January 26 2023, the lower house of the Polish parliament, the Sejm, passed the Family Foundation Act, which will enter into force in May 2023....

Pursuant to today’s judgment of the CJEU in case C-677/21 Fluvius Antwerpen, unlawful consumption of electricity constitutes a supply of goods for consideration subject to VAT, and a distribution network operator (DSO) charging a fee of compensation on this account acts as a...

MDDP advised Adventum Group on the acquisition of the Wola Retro office complex The fund, which belongs to Adventum Group, has just signed an agreement transferring ownership of the buildings from its current owner, Develia Group. The value of the transaction was €69.3 million. Scope...

Cost optimization-oriented payment management as a controlled transaction Payment management to optimize costs of the payment settlement process using the PoB (payments on behalf) model is a controlled transaction – as stated by the District Administrative Court in Warsaw in...

MDDP in the 17th Ranking of Tax Advisory Firms We are pleased to announce that in the latest Ranking of Tax Advisory Firms of Rzeczpospolita, MDDP advisors became leaders in 5 out of 9 individual categories, including 3 categories in which we debuted in the ranking, and immediately...

Over the last few years, activities related to the charging of electric vehicles have given raise to many interpretative doubts whether they should be classified as a supply of goods or a supply of services on the grounds of VAT. These doubts were finally resolved before the Court...

The introduction of the mandatory KSeF (National e-Invoicing System) will undoubtedly affect all issues related to invoicing, circulation of invoices within organizations or exchange of invoices with contractors. This will also concern self-billing, as invoices issued this way are...