MDDP Insight

MDDP Insight

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New businesses and the exemption from transfer pricing analysis
The exemption from transfer pricing analysis in the first year of business raises doubts. Can a new entity...
Trademark in Transfer Pricing – how to determine an arm’s length royalty rate?
A shareholder’s trademark used by a company raises questions about the terms of its use and remuneration...
New PIT progression and higher CIT. How could taxpayers’ burdens change?
Changes to PIT and CIT may increase the tax burden for some taxpayers. Who will benefit from the new...
SAF-T for CIT: Proposed postponement of JPK_ST_KR fixed asset reporting
The Ministry of Finance and Economy has prepared a draft regulation providing for an exemption from JPK_ST_KR...
Does aligning cost base always constitute a transfer pricing adjustment under Article 11e?
For several years, the answer to this question has been subject to debate, as evidenced by the numerous...
Public CbC-R – a report that requires decisions, not just data
Public CbCR is becoming mandatory for the largest corporate groups. What do the new rules mean for reporting...
Excise duty exemption for products containing denatured alcohol – significant EU General Court judgment T-381/25
EU Court on the excise duty exemption for denatured alcohol. What does the ruling mean for manufacturers...
Coca-Cola vs IRS – does a long-standing transfer pricing model really provide protection?
Does the Coca-Cola dispute with the IRS show that years without objections from the tax authorities do...
Robotization Tax Relief: What constitutes an industrial application of a robot?
The fundamental condition for claiming the robotization tax relief is that the acquired equipment must...
Do Polish and foreign self-balancing branches have to report JPK_CIT?
The KIS’s revised 2026 approach reduced the risk of double bookkeeping and excessive JPK_CIT obligations...
Joint and several liability of a tax representative – judgment of the General Court of the European Union
CJEU judgment in Case T-356/25 Rapera: is a tax representative jointly liable for VAT when they only...
Transfer pricing in 2026 – Local File, TPR and Master File deadlines for FY 2025
Although transfer pricing deadlines are a permanent feature of the tax calendar, they still tend to surprise...
KSeF 2026 – the 5 most common mistakes in structured invoicing and how to avoid them
The mandatory National e-Invoicing System (KSeF) fundamentally changes the way transactions between businesses...
The EU Tax Omnibus proposes: fewer formalities, broader exemptions and new incentives for investment
The European Commission has presented a draft directive referred to as the tax Omnibus package. Its main...
IP Box and transfer pricing – where do these two worlds meet?
How to correctly determine the income covered by IP Box, and where do transfer pricing rules come into...
CIT exemption for foreign investment funds investing in Polish real estate – key court rulings and practical implications
New CIT rulings strengthen tax certainty for foreign funds and make Poland more attractive to real estate...
Exemption of cross-border dividends from withholding tax in light of the latest signals from the CJEU
WHT audits are intensifying, and WHT on dividends paid to foreign entities has become a major dispute...
NSA on share valuation: criticizing the method alone is not enough
The judgment of the Polish Supreme Administrative Court (NSA): a tax authority cannot automatically challenge...
TP Statement and non-arm’s length transfer prices – does a CIT adjustment eliminate the risk?
Can a taxpayer confirm in the TPR form that its transfer prices were arm’s length if it has previously...
Free-of-charge share redemption and transfer pricing consequences – recent Polish Supreme Administrative Court rulings
The Supreme Administrative Court (SAC) is increasingly indicating that certain capital transfers may...
Settlement of robotisation tax relief – one-off deduction or depreciation write-offs?
Should the robotics relief be settled together with depreciation, or as a one-off deduction? Diverging...
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