MDDP Insight

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Important general tax ruling of the Minister of Finance on outstanding social and health insurance contributions
Remitter’s payment of outstanding social and health insurance contributions in the part in which they...
Is it enough to update transfer pricing analyses once every three years?
Comparative analysis, also referred to as benchmarking analysis, is basically a key element of a transfer...
Mutual guarantee without remuneration - is it always a free-of-charge performance?
Financial institutions more and more often require guarantees when granting financing to enterprises....
Taxing shifted profits – how to tackle the new challenge in Poland
Bartosz Doroszuk of MDDP offers insights on Poland’s new tax legislation on shifted profits, as the implementation...
TP Statement for 2022 – less formalities, wider scope
Q1 2023 is coming to an end and taxpayers have already familiarized themselves with the changes brought...
End of Q1 2023 - what obligations must be met?
End of Q1 2023 – what obligations must be met? For most taxpayers operating in corporate groups...
Can tax authorities recharacterize transactions made before 2019?
The instrument of recharacterization and non-recognition of transactions was introduced to the transfer...
Mandatory e-invoicing in Poland postponed till July 2024
Janina Fornalik of MDDP explains recent changes to, and potential problems with, the proposed mandatory...
TP adjustment – formal eligibility conditions
Today we are addressing formal conditions to be met only in the case of in minus adjustments. Condition...
Brokerage services in the light of transfer prices regulations
Correctly classifying a brokerage transaction has certainly not been intuitive for taxpayers. Making...
DAC confirms transfer pricing also applies to Estonian CIT
In a recent blog entry we wrote that according to the position of the tax authorities, the choice of...
When is a transfer pricing adjustment possible?
In the regulations is lack a definition of a transfer pricing adjustment (TP adjustment). However, it...
Capital transactions in the light of transfer pricing obligations
Identifying documentation obligations is a key step in completing the tasks imposed by the transfer pricing...
Carbon Border Adjustment Mechanism – updated draft revealed
In connection with the preliminary agreement reached on 14 December 2022 between the European Commission...
OECD has published a document on MAP and APA procedures
On 1 February, OECD released a Manual on the Handling of Multilateral Mutual Agreement Procedures and...
Not only the median constitutes the market level
In its judgment of 28 December 2022, issued by the Voivodship Administrative Court in Białystok (ref....
Challenges and opportunities - new rules in the Polish Investment Zone
Bartosz Głowacki of MDDP analyses the new rules surrounding the Polish Investment Zone, with significant...
The deadline for CBC-P filing is approaching
The deadline for submitting the CBC notification (CBC-P) for 2022 to the Head of KAS is coming soon –...
Sale of shares - how to determine the arm’s length value?
Although part of business operations for years, capital transactions raise doubts among taxpayers from...
The last effort - the Master File...
Unfortunately, some taxpayers will not find the beginning of the year to be a relief after a demanding...
Royalty fee should not always be calculated as a percentage of sales revenue
In order to correctly determine the remuneration for providing an intangible asset, you need not only...
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