MDDP Insight

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Corporate tax
Transfer pricing
VAT
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...
Attention Taxpayers! New sanction! Keep an eye on Master File before it's too late
Group documentation is treated a bit lightly by taxpayers. After the hassle of preparing Local File with...
Automation in Microsoft Excel - how can you use the program's functionalities in your daily work?
In today’s dynamic business environment, organizations face constant challenges to remain efficient...
Valuation techniques, or the so-called "sixth method"
The methods used to verify the transfer price are indicated in Article 11d of the CIT Act, i.e.: the...
CBAM – detailed reporting obligations and new guidance from the European Commission
On 17th August, the European Commission published rules governing the implementation of the CBAM mechanism...
The key role of benchmarking in safeguarding a taxpayer
The primary purpose of a benchmarking analysis is to establish and verify that the terms and conditions...
Cooperation with influencers through barter
Marketing contracts are an area where, in addition to the legal risks, particular attention should be...
Personal affiliations - excluding documentary exemption for Treasury-affiliated companies
Identifying the links between the parties to a transaction is one of the first and at the same time the...
How to manage financial transactions – transfer pricing aspects in Poland
The economic situation in the global markets as well as the increase of banking reference rates, higher...
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VAT classification of sales of commercial real estate as the Organised Part of an Enterprise
Judgment of the Supreme Administrative Court of 28 July 2023 (ref. I FSK 892/18) The recently announced...
Polish provisions restricting the right to be granted interest on overpayments inconsistent with EU law
On 8 June 2023, the Court of Justice of the EU issued a judgment in case C-322/22, in which it stated...
When does a company act as a private investor?
The rule under Polish tax law is a one-off tax levied on the same transaction, whereby – pursuant...
EU customs reform - proposals of the European Commission
On May 17, 2023, the European Commission presented the first package of changes to EU customs law. The...
VAT treatment of NFT tokens in the opinion of the European Commission
On March 21, 2023, the European Commission published a working paper (Working Paper no. 1060 of the EU...
CJEU restricts the possibility of being prosecuted twice for the same offence
In the judgment of 4 May 2023 in Case C-97/21 MV – 98, the CJEU found that provisions of the Member...