MDDP Insight

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VAT
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...
ATAD 2 rules in Poland – latest practice
General rules The regulations on preventing hybrid mismatches in Poland came into force on January 1,...
Minimum income tax returns
On January 1, 2024, the minimum corporate income tax provisions of Article 24ca of the CIT Law will begin...
Local file documentation - the last straight
In 2023, the deadlines for completing transfer pricing obligations for 2022 have been shortened. The...
Draft of Polish withholding tax official guidelines full of controversy
The consultation period for draft withholding tax guidelines could be crucial in addressing the issues...
Intangible assets – what to keep in mind in intra group settlements?
The first-ever scent trademark has been registered in the European Union. Moreover, as much as 79% of...
Linkage and confusion, or how to correctly identify related parties
Identifying the links between parties to a transaction is not only crucial, but also one of the first...
Draft withholding tax clarifications full of controversy before consultation
Or rather, on the premise of beneficial ownership, since, despite the name of the project (‘clarifications...
Safe harbour for low-value-added services - how to ensure the comfort of using a safe harbour mechanism in 2023
Safe harbour is a mechanism to reduce documentation and transfer pricing reporting obligations provided...
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