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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...
The type of base interest rate and margin for 2023 announced!
A new announcement by the Minister of Finance on the type of base interest rate and margin for the purposes...
What happens if you fail to meet transfer pricing obligations for 2021? Changes starting from 2022.
What happens if you fail to meet transfer pricing obligations for 2021? Changes starting from 2022. Sanctions...
Enhanced tax exemptions for holding companies in Poland
Magdalena Zamoyska and Monika Grobelska of MDDP explain a series of amendments for 2023 that are expected...
What's new in transfer pricing - an amendment to the Polish Deal
The amendment to the Polish Deal, which has recently come into force, has brought favourable changes...
Significant changes to the Polish Holding Company
The Polish Holding Company (PHC) is a solution that has been effective in the CIT Act since 1 January,...
National regulations are superior in defining the concept of the arm’s length principle
On 8 November 2022[1], the Court of Justice of the European Union (‘the CJEU’) annulled the decision...
Withholding tax 2023
Autumn has come and it has been followed by another changes in tax regulations, including the flat-rate...
The license for trademarks should also be settled arm’s length
Transactions involving intangible assets are among related-party transactions causing the greatest difficulties...
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