MDDP Insight

MDDP Insight

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Transfer pricing
VAT
Health insurance contributions on reimbursement of travel expenses for board members appointed by resolution
Reimbursement of travel expenses for board members is, as a rule, exempt from income tax (PIT) and social...
Transfer pricing adjustments and VAT – The Arcomet Case
As part of our series TP and VAT, where we discuss key issues concerning intra-group transactions (Intra-group...
Application of Guidelines to payments to investment funds
The tax Guidelines published by the Ministry of Finance concerning the application of the so-called beneficial...
Excise duty on alcohol used in biocidal products – judgment and implications for the industry
The Voivodship Administrative Court in Gliwice, in a non-final judgment (ref. III SA/Gl 895/24), upheld...
Simple joint-stock company and income tax – what do you need to know?
Since 2021, it has been possible to conduct business activity in the form of a simple joint-stock company...
Estonian CIT versus the decision on support in the Polish Investment Zone – the latest interpretation by the Director of the National Tax Information Service and its significance for entrepreneurs
For many entrepreneurs, Estonian CIT means an opportunity for simplified settlements and greater financial...
Estonian CIT and the employment condition – tax authorities versus the Supreme Administrative Court
Several weeks ago, this blog provided commentary on the Supreme Administrative Court ruling of 15 May...
Practical significance of the explanations of 3 July 2025 concerning WHT in relation to the LTA concept
The tax explanations concerning the application of the beneficial owner (BO) clause significantly clarify...
TPR Profitability – analysis, challenges and finalisation of data for transfer pricing purposes
TPR (Transfer Pricing Report) is a key obligation for taxpayers carrying out transactions with related...
Climate justice in Hague. Has the UN Court opened the path to reparations?
On 23 July 2025, the International Court of Justice (ICJ) issued an advisory opinion concerning the obligations...
The concept of shared personal and asset substance in the new WHT Explanations
The latest explanations issued by the Ministry of Finance on 3 July 2025 regarding withholding tax (hereinafter:...
Estonian CIT and company reorganisations – new protective opinion from the Head of the National Revenue Administration
On 1 August 2025, the Head of the National Revenue Administration issued a protective opinion (ref. DKP16.8082.1.2025),...
Substance related to assets and personnel as a key element of actual economic activity in light of the 2025 Withholding Tax Explanations
Asset and personnel substance is one of the most important elements in determining the status of the...
Debt capacity - when is it worth considering in transfer pricing?
“Debt analysis,” “debt capacity,” “analysis of debt servicing ability” – many terms exist in the world...
New mileage rates: regulations will also apply to electric vehicles
Work is underway on a new regulation by the Minister of Infrastructure, which will update the rules for...
A new perspective from the CJEU on transfer pricing adjustments and VAT – the Arcomet Case (C-726/23)
Continuing the TP and VAT series, in which we discuss the most important cases regarding intra-group...
Sponsorship for sports clubs – tax consequences
The sports industry is constantly growing year on year, and its development is closely linked to the...
Economic power in light of the WHT Explanations – is this the end of uncertainty?
On 9 July 2025, the Minister of Finance published the long-awaited tax explanatory notes regarding so-called...
Cryptocurrency tax in Poland: PIT-38 explained for investors
If you bought or sold cryptocurrencies (or, to use the formal term, virtual currencies) during the tax...
What is ‘product not previously offered’ in the context of the expansion relief?
The expansion relief (under Article 18eb of the CIT Act) is an attractive incentive for entrepreneurs...
Tax authorities push for higher RET on unsold residential properties
Many believed that the long-standing disputes over the correct property tax rate for residential units...
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