MDDP Insight

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Transfer pricing
VAT
Gifts of an insignificant value and samples – about "donations" which you will not pay VAT on
On the VAT ground, if someone passes on some goods to another person for free, (i) sometimes VAT has...
Last call: Significant changes to take info account before submitting TPR
When planning to submit transfer pricing information (hereinafter: TPR) for the tax year beginning after...
Impact of classification of goods on customs duties - opinion of the Advocate General of the CJEU in case C-104/23
On January 18, 2024, the Advocate General of the Court of Justice of the European Union issued an opinion...
What is subject to VAT taxation? About the rules worth knowing and exceptions that confirm the rule
When it comes to taxes – including VAT – one of the fundamental questions that taxpayers often ask themselves...
Who submits the TPR form after a merger?
The dynamically changing economic situation, continuous development of competition in most industries...
CJEU reminds that VAT taxpayers do not have to control their contractors
The Court of Justice of the European Union, in its judgment of 11 January 2024 in Case C-537/22, reminded...
Planning, rather than mere compliance, is the essence of transfer pricing
For most taxpayers, transfer pricing is associated with numerous and complex formal requirements that...
What will change in the JPK VAT in terms of KSeF?
Despite the festive period and personnel changes in the structures of the Ministry of Finance, work on...
Use of OECD guidelines in EU jurisprudence
At the end of last year, the outcome of the Amazon group’s tax dispute was widely reported in the...
When does a member of a company's board of directors carry out VAT-taxable activities?
On 21 December 2023, the CJEU handed down a long-awaited judgment on the VAT taxation of board members’...
SUP fee - ecology yes, but with VAT?
This year, when selling food or beverages in single-use packaging to consumers, a SUP fee they must be...
Changes in the base interest rate and margins – announcement regarding transfer pricing!
The new Notice of the Minister of Finance on the announcement of the type of base interest rate and margin...
Are transactions between spouses subject to transfer pricing obligations?
On July 3, 2023, a parliamentary interpellation was submitted to the Minister of Finance regarding the...
TP adjustments - to show or not to show in VAT settlements?
Many companies in capital groups make an annual price adjustment in transactions with a related company...
Can hard-to-value intangibles actually be problematic?
We recently wrote on our blog about intangible assets and accounting for them. In this post, we would...
Factors affecting the tariff classification of goods
The Court of Justice of the European Union (CJEU) confirmed in its judgment of 16 November 2023 (C-366/22...
What not to forget when filling out the TPR for 2022?
Although the deadlines for filing the transfer pricing information (TPR) form for 2022 are to be extended...
Benchmarking analysis or compliance analysis - how to report in the TPR form?
One of the key elements of transfer pricing documentation is a transfer pricing analysis. It can be prepared...
Capital increases and surcharges vs. TP obligations
One of the types of controlled transactions that can be carried out between related parties are capital...
Technical aspects of submitting for the 2022 TPR form. How to do it?
The deadline for submitting the 2022 TPR form (for taxpayers whose tax year coincides with the calendar...
TPR as a tool for typing for tax audit
When trying to complete the TPR form, it is good to remember what the primary purpose of this reporting...
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