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...

The innovative employees tax relief, regulated in Article 18db of the CIT Act, was introduced into the Polish legal system as a tool to support entrepreneurs conducting research and development (R&D) activities who were unable to take full advantage of the R&D relief (Article...

In recent months, the topic of sustainability and related reporting obligations has remained one of the most pressing challenges for thousands of companies in Poland. This is largely due to the EU’s CSRD directive as well as the new, more demanding ESG reporting standards in the form...

The Supreme Administrative Court’s ruling of 15 May 2025 (ref. II FSK 163/25) provides clarity on one of the challenging and ambiguous issues concerning Estonian CIT. This refers to the condition of maintaining an appropriate level of employment for a minimum of 300 days in...

The Polish Holding Company (PHC) is an institution that was supposed to encourage the establishment of holding structures in Poland by offering CIT exemption for dividends and income from the sale of shares in subsidiaries. The planned amendment to the regulations may make it easier...

Transfer pricing analysis forms the backbone of the Local File and the TPR (Transfer Pricing Report) form. Find out how to avoid income reassessments and prepare an analysis robust enough to pass a customs and tax audit. Introduction At first glance, everything appears to be in order....

MDDP with 10 nominations in ITR EMEA Tax Awards 2025  International Tax Review has announced this year’s shortlist, and MDDP has once again been recognised among Europe’s leading advisory firms, securing an impressive 10 nominations – both for team achievements and individual excellence. Regional...

Clarified beneficial ownership rules and introduction of overseas investment fund exemptions Ministry of Finance has recently published long-awaited explanatory notes on Withholding Tax (WHT), addressing long-standing ambiguities, which taxpayers had to face. These notes concern particularly...

The introduction of a tax exemption known as the Polish Holding Company (PHC) into the Corporate Income Tax Act was intended to increase Poland’s attractiveness as a location for investment structures and to create a competitive tax environment. It is difficult not to notice...

New European Commission initiative At the beginning of July 2025, the European Commission published recommendations on the design of tax incentives to support investment in clean technologies and industrial decarbonisation. This document is part of the Clean Industrial Deal, an EU...

A fundamental requirement for Estonian CIT is that the majority of revenue must be derived from operating activities. In practice, this means that less than half of the company’s total gross revenue may come from so-called passive sources. In the list compiled by the legislator,...

MDDP advised the Adventum Group on the combined acquisition of four properties under a sale and leaseback structure MDDP experts once again had the pleasure of supporting the Adventum Group – this time in a transaction involving the acquisition of industrial properties, including...

Organised part of an enterprise Tax regulations define an organised part of an enterprise [hereinafter: OPE] as a set of assets – tangible and intangible, including liabilities – organisationally and financially separated within an existing enterprise, intended to perform specific...