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Family foundations – draft tax changes from 2026
The Ministry of Finance has published draft amendments to the Family Foundation Act, which are to come into force on January 1, 2026.   Key changes concerning family foundations Taxation of the sale of assets within 36 months of acquisitionThe foundation will pay 19% CIT on income...
Cash pooling and withholding tax in light of the WHT Explanatory Notes of July 3, 2025 – question without answers
The modern world of finance is dominated by liquidity management. Companies, especially those belonging to international capital groups, focus on centralization in order to effectively manage cash surpluses and deficits. Cash pooling, a system that enables cash flow management within...
Estonian CIT under scrutiny by tax authorities
The data presented in the Ministry of Finance’s response to a parliamentary question[1] is a warning sign for entrepreneurs that the correct application of Estonian CIT rules may be more challenging than many of them had anticipated. The information presented shows that the...
Health insurance contributions on reimbursement of travel expenses for board members appointed by resolution
Reimbursement of travel expenses for board members is, as a rule, exempt from income tax (PIT) and social security contributions.
Transfer pricing adjustments and VAT – The Arcomet Case
As part of our series TP and VAT, where we discuss key issues concerning intra-group transactions (Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT | MDDP), we covered the Arcomet case (C-726/23) and the opinion of the Advocate General...
Upcoming challenges for non-employee forms of engagement and B2B contracts – draft bill extending the powers of PIP
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
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
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...
General interpretation by the Ministry of Finance: how to understand the CJEU rulings on joint and several liability?
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 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...
Application of Guidelines to payments to investment funds
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
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,...
Excise duty on alcohol used in biocidal products – judgment and implications for the industry
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...
Simple joint-stock company and income tax – what do you need to know?
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...
Estonian CIT versus the decision on support in the Polish Investment Zone – the latest interpretation by the Director of the National Tax Information Service and its significance for entrepreneurs
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...