On 1 August 2025, the Head of the National Revenue Administration issued a protective opinion (ref. DKP16.8082.1.2025), which is of significant importance for companies planning to switch to Estonian CIT after undergoing reorganisation. In the case in question, the authority found...

Ministry of Finance announces changes in the taxation of family foundations from 2026 On 8 August 2025, representatives from the Ministry of Finance and the Ministry of Economy announced an increase in the taxation of family foundations. According to the Ministry’s declarations,...

Asset and personnel substance is one of the most important elements in determining the status of the beneficial owner [hereinafter: ‘BO’] for the purposes of withholding tax [hereinafter: ‘WHT’]. The tax explanations published on 3 July 2025 by the Polish Ministry of Finance concerning...

“Debt analysis,” “debt capacity,” “analysis of debt servicing ability” – many terms exist in the world of transfer pricing, but they all refer to the same issue. It is no longer a secret that tax authorities, when examining financial transactions, check not only the level of applied...

GloBE – automatic exchange of information – first signatories of the multilateral agreement (GIR-MCAA) and other tools for handling GloBE. On 6 August 2024, a list of 14 signatories to the multilateral agreement on information exchange GloBE (GIR-MCAA, GloBE Information Return-Multilateral...

On August 1, 2025, the CJEU issued its long-awaited judgment on the reclassification of transactions from intra-Community supply to export in a case concerning a Polish taxpayer (C‑602/24). Facts The case concerns a situation where the initial arrangements between the parties to the...

Work is underway on a new regulation by the Minister of Infrastructure, which will update the rules for reimbursing the costs of using a private vehicle for business purposes (known as mileage rates). The planned changes will not only increase the rates but will also introduce clear...

Continuing the TP and VAT series, in which we discuss the most important cases regarding intra-group settlements (see: Intra-group settlements under the scrutiny of the CJEU – key issues in transfer pricing and VAT), this time we are looking at the Arcomet case (C-726/23), which introduces...

The sports industry is constantly growing year on year, and its development is closely linked to the increasing level of sponsorship. Sponsors are a kind of stimulus for the development and expansion of Polish sports clubs, both in the domestic and international sports world. However,...

On 9 July 2025, the Minister of Finance published the long-awaited tax explanatory notes regarding so-called beneficial owner clause for withholding tax purposes (hereinafter: WHT Explanatory Notes). Their publication is of significant importance for withholding tax remitters and...

If you bought or sold cryptocurrencies (or, to use the formal term, virtual currencies) during the tax year, you will need to report either the income you earned or the costs you incurred in your annual PIT-38 return. The deadline for filing is April 30 of the following year. This...

The expansion relief (under Article 18eb of the CIT Act) is an attractive incentive for entrepreneurs who want to develop sales of their products. One of the conditions for applying the relief is an increase in revenue from the sale of own products, including products not previously...

The Director of the National Tax Information Service (KIS) has once again emphasised that remuneration paid to a company’s proxy, who is also a related entity, is taxable as income from hidden profits. For instance, on 17 April 2025, the authority issued an individual interpretation...

Many believed that the long-standing disputes over the correct property tax rate for residential units owned by businesses would be resolved following the resolution issued by the Supreme Administrative Court (NSA) in a panel of seven judges[1]. The Court clearly stated that when...

Poland proposes overhauling foreign fund tax exemption to align with EU law The recently published amendment to the CIT act constitutes an answer to the taxpayers’ doubts concerning rules on the tax exemption for foreign investment funds. The need for new legislation stemmed from...