We have some good news for taxpayers right before the end of the year and the beginning of intensive works on documenting and reporting transactions with related parties and tax haven entities. On 21 October (Friday), the third version of the TPR-C Guidebook was published on the Ministry...

In the ruling no. I SA/Gl 233/22 of 31 August 2022, the District Administrative Court in Gliwice repealed the decision of the Head of the Silesian Customs and Tax Office in Katowice on the reduction of CIT in 2016. The case concerned the acquisition and lease of trademarks from a...

On 13 October 2022, the amendment to the Commercial Companies Code entered into force[1]. It introduced provisions on the group of companies, including a new instrument: binding instructions. According to the new provisions of the holding law, the parent company may issue a binding...

National Teachers’ Day in the Ukrainian School in Warsaw Today we celebrate Teachers’ Day in Poland. On top of appreciating teachers, this is a great opportunity to remind about the work of the Educational Center Children of Ukraine Foundation, with which we cooperate together...

Transfer pricing continues to attract the attention of tax authorities. Major additional income assessments and successfully completed controls (from the perspective of tax authorities) are summarized by the National Revenue Administration – it releases information on the amount of...

On 13 July 2022, the National Working Group (NGR) for reform of reference index was established. It was tasked with introducing a new interest rate reference index in place of WIBOR. The NGR features, among others, the representatives of te Ministry of Finance, the Bank Guarantee...

MDDP on Polish Taxes I Posting workers to Poland – the most important tax and legal regulations November 23, 2022 at 10:00 a.m. Posting workers to Poland is a multifaceted process in the tax and legal context. The foreign employers should comply with EU regulations as well as with...

Magdalena Dymkowska of MDDP provides a guide to the vagaries of the Polish transfer pricing regulations and explains why the applicability of the arm’s-length rule may leave multinational companies somewhat surprised. Multinational companies that are familiar with transfer pricing...

Keep your arm’s-length distance – how to meet Polish TP obligations Multinational companies that are familiar with transfer pricing (TP) issues in their countries might raise their eyebrows over the kinds of transactions that are subject to the arm’s-length rule in Poland. Usually,...

Individuals responsible in a company for financial matters should not associate transfer pricing only with compliance obligations. Already at the stage of planning transactions with related entities, it is worth remembering about TP regulations. This will ensure the transaction is...

Starting 2021, related entities with the status of a micro or small business may prepare local files without a benchmarking analysis. Also in the TPR form, taxpayers do not fill in the boxes related to the analysis. Until now, these entities were only released from the need to file...

Property tax in the real estate business with elements of investment accounting October 27, 2022 | 10:00 a.m.: Register Issues related to property tax seem to be relatively easy at first glance. In practice, a lot of doubts arise, especially related to the scope of taxable facilities...

The latest interactive TP-R forms were published on 28 September (Wednesday) on the Ministry of Finance’s website. The forms are relevant for the IC-transactions carried out FY 2021. The release results from the regulations published by the Polish Ministry of Finance (for CIT and...

The CIT Act-introduced transfer pricing regulations target primarily controlled transactions made between related entities. However, not everyone is aware that they also apply to transactions with third parties having their registered office or management in the territory or in a...

Tax changes related to employment in Poland from the payer’s perspective New regulations that have significantly changed the Polish tax system for the second time in 2022 came into force on July 1. The tax amendment, the so-called Polish Deal 2.0, modifies the personal income tax...