Upcoming challenges for non-employee forms of engagement and B2B contracts – draft bill extending the powers of PIP The Ministry of Family, Labour and Social Policy has published long-awaited a draft act expanding the powers of the National Labour Inspectorate [PIP].   Who will be...

Simplified mergers are now clearly neutral for CIT purposes Amendment to the CIT Act within the framework of Energy Law changes On August 5, 2025, the Act amending the Energy Law and certain other acts clarified the Corporate Income Tax (CIT) regulations regarding mergers conducted...

Poland’s new explanatory guidelines ‘create tension’ with EU over beneficial ownership The Polish Ministry of Finance published explanatory guidelines (hereinafter: the Guidelines) on the application of the beneficial owner (BO) clause in Withholding Tax (WHT). These document has...

On 29 August 2025, the Minister of Finance and Economy issued a general interpretation regarding the practical application of the Tax Ordinance (Ordynacja podatkowa) concerning the liability of management board members. This interpretation responds to questions raised after the Court...

The e-Invoicing Act (“KSeF 2.0”) published in the Journal of Laws The Act of August 5, 2025, amending the VAT Act and the so-called Act on the National e- Invoicing System (KSeF), introducing mandatory KSeF, was published on September 1, 2025, in the Journal of Laws of the Republic...

The tax Guidelines published by the Ministry of Finance concerning the application of the so-called beneficial owner clause for withholding tax purposes (hereinafter: Guidelines) are intended to clarify the rules for applying this clause in the context of the withholding tax collection...

MDDP advised Ghelamco on the sale of the VIBE building  Experts from MDDP Michalik Dłuska Dziedzic i Partnerzy provided tax advisory services to Ghelamco on the sale of the VIBE building to Manova Partners. The transaction, one of the largest office deals in the CEE region in 2025,...

The Voivodship Administrative Court in Gliwice, in a non-final judgment (ref. III SA/Gl 895/24), upheld the position of the tax authorities and ruled that disinfectant liquid is subject to excise duty. Why is excise duty on biocidal alcohol controversial? Recently, excise duty on...

Since 2021, it has been possible to conduct business activity in the form of a simple joint-stock company (PSA). The PSA was intended to address the challenges of the modern economy – no barriers to entry, simplified profit distribution and faster liquidation, in short – the ideal...

For many entrepreneurs, Estonian CIT means an opportunity for simplified settlements and greater financial liquidity, but at the same time – a number of conditions to be met. One of them is the prohibition of combining Estonian CIT with the privileges resulting from the decision on...

Several weeks ago, this blog provided commentary on the Supreme Administrative Court ruling of 15 May 2025 (ref.). II FSK 163/25 [1] provided a clear definition of the interpretation of the employment condition in Estonian CIT. The Supreme Administrative Court ruled that the requirement...

The tax explanations concerning the application of the beneficial owner (BO) clause significantly clarify and, we hope, will facilitate the application of the look-through approach (LTA). The application of the LTA may prove crucial for international capital groups where WHT-taxable...

TPR (Transfer Pricing Report) is a key obligation for taxpayers carrying out transactions with related entities. Its purpose is to provide the tax authorities with essential information about transactions, including the reported profitability. TPR reporting is not merely a formality...

In business practice, situations frequently arise in which one entity incurs the cost of a service or goods and subsequently passes it on to another entity. A classic example is the so-called re-invoice – i.e., the resale of a service without adding one’s own margin, usually “at cost.” To...

On 23 July 2025, the International Court of Justice (ICJ) issued an advisory opinion concerning the obligations of states with regard to climate protection. This case originated from an initiative by students from the Pacific Island Students Fighting Climate Change, who demanded actions...