MDDP Insight

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Transfer pricing
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Exemption of dividends from withholding tax without the requirement of beneficial ownership status – significance of the Head of the National Tax Information Service’s ruling
The condition of beneficial ownership has remained one of the key issues in withholding tax for many...
Personal links and the exemption from transfer pricing documentation (article 11n(5) of the Polish Corporate Income Tax Act)
Personal links and the TP documentation exemption – when Article 11n(5) of the CIT Act applies and what...
Companies with a shifted financial year – transfer pricing obligations
Companies with a shifted financial year – check your transfer pricing obligations. TP audit, documentation,...
CbC-P – who is required to file and when in 2026?
The deadline for CBC-P for 2025 is 31 March 2026; check who is required to file, what data must be reported,...
Transfer pricing adjustments – a tool for restoring the arm’s length nature of controlled transactions
Transfer pricing adjustments as a tool for restoring arm’s length conditions. Legal requirements, tax...
“Total working time” in R&D tax relief – how should it understood?
Eligible costs under the research and development (R&D) tax relief include, among others, expenses...
Transfer pricing adjustments – global challenges, domestic obligations
Transfer pricing adjustments in Poland and abroad. The arm's length principle, OECD guidelines, tax conditions,...
Year-end in transfer pricing – obligations, risks and key actions for 2025/2026
Year-End in Transfer Pricing: Key Documentation Obligations and Actions for 2025/2026 to Minimise Tax...
First general interpretation of real estate tax in years
On December 1, 2025, the Minister of Finance and Economy issued a general interpretation[1] regarding...
Master File and Withholding Tax (WHT). What does a Polish company in an international group need to know?
How does the Master File impact withholding tax (WHT) in Poland? Review the key risks, obligations, and...
Links with the State Treasury and the transfer pricing documentation requirement
Discover the latest Supreme Administrative Court (NSA) ruling and individual tax interpretation regarding...
Financial transactions in transfer pricing. What to watch out for to avoid errors and penalties?
Financial transactions in transfer pricing: what to watch out for to avoid mistakes and penalties? We...
Business valuation - how to determine a company’s value step by step
Learn how to carry out a professional business valuation. Discover the methods, stages and key factors...
Choosing the Estonian CIT and the delayed signing of the financial statement – Ministry of Finance softens its approach
Change of taxation form to Estonian CIT A company may opt for Estonian CIT taxation during the tax year,...
Did the Supreme Administrative Court grant a VAT exemption for erotic performances?
In recent days, much attention has been drawn to the judgment of the Supreme Administrative Court (NSA)...
Tax after leaving the Estonian CIT – how does the lump sum tax on company income work? New interpretation by the Director of the National Tax Information Service 2025
The departure of the Estonian CIT has led to a number of concerns being raised among entrepreneurs. Following...
CJEU judgment in the Xyrality case C-101/24 – Is the platform liable for VAT?
xyrality: CJEU ruling C-101/24 – is the platform liable for VAT? Analysis of Articles 28 and 9a, impact...
WHT explanations – have holding companies finally been understood in terms of withholding tax?
WHT explanations – have holding companies gained understanding in withholding tax? What is the opinion...
Estonian CIT and bond purchases – hidden risk of losing the right to a lump sum regime
Estonian CIT conditions One of the conditions of Estonian CIT is the appropriate structure of the company’s...
Hidden gains in the draft amendment for 2026 – what may change in Estonian CIT?
The draft amendment to the income tax laws of September 16, 2025, provides for changes in the regulations...
Last chance to prepare the 2024 Local File!
Local File 2024: discover why the reliable preparation of transfer pricing documentation and consistency...
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