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MDDP Insight

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Transfer pricing
VAT
Qualification of voucher sales for VAT purposes in case of potential fraud
When distinguishing between single-purpose vouchers (so-called SPVs) and multi-purpose vouchers (so-called...
Arm's length principle of loan is not only about the interest rate
Financial transactions are one of the most common transactions between related parties and also most...
The acceptance protocol and the moment of arising of VAT liability for the provision of a service
Judgment of the Voivodship Administrative Court in Warsaw of April 18, 2024, ref. III SA/Wa 8/24 It would...
Benchmarking study – courts also prioritize quality!
With each passing year, courts increasingly confirm that a properly prepared benchmarking study can be...
What's next for VAT in Digital Age after VAT EXPERT GROUP meeting?
Following the meeting of the VAT EXPERT GROUP in Brussels on 18 March, the next steps for VAT in the...
Transfer pricing – a springboard for business growth
Today, we present the fourth and final entry in our series on transfer pricing. From previous posts,...
Transfer pricing adjustments under the magnifying glass of tax authorities - trends in 2023
Price adjustments are still not a clear-cut issue and raise questions for taxpayers. In 2023, administrative...
How can you tell if prices are at arm’s length?
The fundamental rule in transfer pricing is the arm’s length principle. When applied correctly, it ensures...
The importance of benchmarking quality in financial transactions
Intra-group loan Intra-group loans, like other related party transactions, should be made on an arm’s...
Do you know that you are a “related party”?
Have you heard of the “six degrees of separation” theory? It’s a concept that assumes that, as...
Business development and the potential of tools for transfer pricing planning
In the dynamic business world, planning of settlement between related parties is becoming an essential...
What's next for National e-Invoice System (KSeF)?
One thing is certain: there is no turning back from National e-Invoice System [hereinafter: KSeF]. This...
Negative electricity and gas prices and reverse charge VAT
Judgment of the Provincial Administrative Court (WSA) in Warsaw of 21 February 2024, ref. no. III SA/Wa...
APA-C as a report on the implementation of the APA agreement
An APA (advance pricing arrangement) is an agreement on the transfer price applied in transactions between...
Transfer pricing is...
When we talk about transfer pricing, we’re definitely thinking about transferring funds. And probably...
Taxpayer with the right to adjust consumer sales VAT rate
By the judgment of March 21st, 2023 (ref. C-606/22, Director of the Tax Administration Chamber in Bydgoszcz),...
Keep transfer pricing in mind when planning ESG
Recently, there has been a noticeable increase in interest in ESG topics. This is due to two reasons:...
Bad debt relief: creditor entitled to interest
In its judgment of 29 February 2024[1], the CJEU ruled that Member States may impose time limits on a...
PIT on rental via online platforms in Poland and tax obligations for foreign property rental income
Short-term rental of real estate via online platforms is becoming an increasingly popular way of earning...
New green obligations for importers and exporters will come into force in 2024
The European Union is about to take another major step towards reducing its impact on global deforestation...
The deadline for CBC-P filing is approaching
The deadline for submitting the CBC notification (CBC-P) for 2023 to the Head of KAS is coming soon –...
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