On 1 January 2026, the transitional period for the CBAM (Carbon Border Adjustment Mechanism) will come to an end. The entry into force of the full CBAM regulations will introduce new administrative and reporting obligations for importers of goods from outside the EU. At the same time,...

The resolution of the Supreme Administrative Court (NSA) of 16 June 2025 (case no. III FPS 1/25) settles a dispute regarding the delivery of an enforceability warrant issued under Article 155b § 1 of the Act on Enforcement Proceedings in Administration. The NSA held that such a warrant...

In the first article of our TP & VAT series (link: https://www.mddp.pl/intra-group-settlements-under-the-scrutiny-of-the-cjeu/ ), we outlined the general background to recent rulings by the Court of Justice of the European Union (CJEU) in this area. Today, we delve deeper into...

Poland’s Estonian CIT: an increasingly attractive option for domestic and foreign investors Poland’s Estonian-style corporate income tax (CIT) regime has become an increasingly popular choice among taxpayers. Introduced in 2021 and significantly liberalised in 2022, the system has...

KSeF – the Final Stage of the Legislative Process On 17 June 2025, the Council of Ministers adopted the draft act implementing the mandatory National e-Invoicing System (KSeF), marking the final stage of the legislative process. It appears that no major amendments are expected during...

Starting in 2026, new regulations on the automatic exchange of information regarding crypto-asset transactions will come into force across the European Union. These rules will introduce mandatory reporting obligations for a broad range of entities operating in the crypto sector –...

Tax challenges in the construction sector The construction industry in Poland is facing many challenges – ranging from labor shortages, increasing material costs, through energy efficiency requirements, to tax implications. Such operational and financial hurdles create an increasingly...

Mandatory e-invoicing in Poland postponed till July 2024 Poland’s Ministry of Finance has approved a phased introduction of mandatory B2B e-invoicing through the National e-Invoice System (KSeF). Initially, in-scope are large enterprises with over PLN 200 million of annual revenue...

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...

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)....