Lump-sum tax on corporate income [Estonian CIT], as a very attractive form of taxation for individuals, is steadily gaining popularity. This is evidenced by the fact that the number of taxpayers subject to Estonian CIT is increasing every year. One interesting aspect of Estonian CIT...

Many taxpayers living and working abroad ask themselves: does the mere fact that my family resides in Poland mean that I am still considered a Polish tax resident? The answer is not straightforward. The mere fact that a spouse or children live in Poland does not determine that the...

Does a gratuitous guarantee granted to a taxpayer subject to Estonian CIT by a related entity give rise to a transfer pricing documentation obligation? According to DKIS [1] – yes – if the value of the guarantee exceeds the threshold of PLN 10 million, the taxpayer will be required...

Entrepreneurs under increasing pressure – MDDP and Confederation Lewiatan report points to uneasy relations with tax authorities The tax advisory firm MDDP has published a report entitled “Entrepreneurs under the fiscal microscope 2025. “Entrepreneurs under the fiscal...

The arm’s length principle applies to all entities conducting transactions with related parties and to all transactions – regardless their value. Even if a transaction does not exceed the documentation thresholds and does not trigger the obligation to prepare local transfer...

Family foundations have been part of the Polish legal system for over two years and have naturally become a popular tool for succession planning. As they gain traction, questions have arisen regarding the permissibility of accumulating and disposing of digital assets by family foundations,...

KSeF 2.0 – status at the beginning of June 2025 The package of regulations setting out the final shape of the KSeF published on Friday 30 May (formally a draft dated 23 May 2025), is expected to reach the deliberations of the SKRM on the day of writing this article (5 June)....

Does a free of charge surety granted to a taxpayer subject to Estonian CIT give rise to a tax obligation to recognise income as hidden profits or revenue from free of charge benefits? The conclusions of the latest individual tax ruling[1] indicate that it does not.   Hidden profit...

Recent discussions have focused on the EU institutions’ evolving stance on ESG (Environmental, Social and Governance) reporting. A central element of these changes is the so-called Omnibus Package, which introduces substantial amendments to both existing and forthcoming regulations—particularly...

The issue of intra-group transactions in the context of value-added tax (VAT) is increasingly attracting the attention of the Court of Justice of the European Union (CJEU). Recent cases underscore the importance of delineating the boundaries between direct tax (CIT) and indirect tax...

The Offline24 mode – as explicitly described by the Ministry of Finance – is considered the most significant enhancement introduced to support entrepreneurs in implementing the National e-Invoicing System (KSeF). But is it truly a facilitation, or rather a trap resulting from not...

Can the payment of remuneration for the redemption of shares, financed from profits earned before the implementation of Estonian CIT, result in lump-sum taxation of company income? Although it may appear that profits once subject to taxation should not be subject to further taxation,...

Cryptocurrencies are becoming an increasingly common means of settlement, including in financial transactions – such as lending or collateral. It is worth taking a look at what tax implications are associated with the use of cryptocurrencies in such situations. Lending in traditional...

Recently issued individual interpretations indicate that tax authorities have inconsistent positions on the classification of lease or rental costs from related entities as so-called hidden profits. While the regulations remain consistent, the authorities’ positions are subject...

The Organisation for Economic Co-operation and Development (OECD) plays a pivotal role in shaping the global tax landscape, particularly in the context of the digital economy. Its objective is to establish a more equitable and predictable international tax framework that addresses...