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...

Deadlines for transfer pricing obligations in Poland – TPR form and the Local File for 2024 – are approaching fast. Find out how much time is really left, which mistakes to avoid, and why acting now – before the end of summer – is your best option. Only 60 days after the summer break That’s...

Work on draft Unshell Directive on hold – member states prefer DAC6 changes The Unshell Directive (ATAD3) is about companies without significant activities. It was intended to set an EU standard for the minimum substance of companies to prevent tax avoidance. The DAC 6 in the...

After years(!) of work marked by long periods of downtime and uncertainty, but also sudden twists and turns, it seems that the finish line of the legislative marathon entitled the mandatory KSeF is finally in sight. Let us recall that the first drafts envisaged the entry into force...

WHT Explanatory Notes from 3rd July, 2025 on the application of the so-called beneficial owner clause for withholding tax purposes On July 9th; 2025 the long-awaited WHT Explanatory Notes regarding the application of the so-called beneficial owner clause for withholding tax purposes...

On 16 June 2025, the Supreme Administrative Court (NSA) declined to adopt a resolution in a case of significant importance to the practice of VAT refunds. The central legal issue concerned whether administrative courts, when reviewing an order to extend the deadline for a VAT refund,...

Extension of tax exemption for foreign investment funds The Ministry of Finance has published a draft amendment to the Corporate Income Tax (CIT) Act, responding to key judgements of the Court of Justice of the European Union (CJEU). The proposed regulations aim to eliminate the inconsistencies...

On 3 July 2025, the CJEU once again spoke on the VAT treatment of intra-group transactions – this time in judgment C-808/23 Högkullen. Factual state Högkullen AB, the Swedish parent company in the real estate management group, operated solely in the area of ​​managing subsidiaries...

For many taxpayers, transfer pricing (TP) compliance forms a crucial part of their annual tax closing procedures. The period from October to December is typically intensive –preparing the Local File and submitting the TPR-C form requires precision and coordination across multiple...

The tax authorities have changed their position on the so-called repeated non-monetary services provided by partners in limited liability companies with Estonian CIT, based on Article 176 of the Commercial Companies Code. Repeated benefits result from the shareholders’ obligation,...

On 24 June 2025, the Supreme Administrative Court (SAC) once again questioned the tax authorities’ approach to the taxation of foreign dividends and interest. The case concerned the possibility of deducting tax paid abroad from the Polish flat-rate tax (19%). For years, tax...