MDDP Insight

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VAT
Innovative employees tax relief – Is it available for companies in a Tax Capital Group?
The innovative employees tax relief, regulated in Article 18db of the CIT Act, was introduced into the...
Omnibus is not a reprieve. ESG remains a business imperative
In recent months, the topic of sustainability and related reporting obligations has remained one of the...
The NSA has adopted a more flexible approach to the Estonian CIT, reducing the requirement for rigid formalities to 300 days of employment
The Supreme Administrative Court’s ruling of 15 May 2025 (ref. II FSK 163/25) provides clarity...
Less paperwork when selling shares – planned changes at the Polish Holding Company
The Polish Holding Company (PHC) is an institution that was supposed to encourage the establishment of...
Transfer pricing benchmarking 2024 - how to prepare an analysis that will withstand a tax audit
Transfer pricing analysis forms the backbone of the Local File and the TPR (Transfer Pricing Report)...
Polish Holding Company – important ruling of the Supreme Administrative Court on the residence of shareholders
The introduction of a tax exemption known as the Polish Holding Company (PHC) into the Corporate Income...
Tax boost for green transition – European Commission recommends tax incentives for clean industry
New European Commission initiative At the beginning of July 2025, the European Commission published recommendations...
Forward contracts do not always deprive Estonian CIT
A fundamental requirement for Estonian CIT is that the majority of revenue must be derived from operating...
Disposal of an organised part of an enterprise – what does it involve, what are the tax risks and how can they be secured?
Organised part of an enterprise Tax regulations define an organised part of an enterprise [hereinafter:...
Transfer Pricing Obligations in Poland – Time Is Running Out for TPR and the Local File 2024
Deadlines for transfer pricing obligations in Poland – TPR form and the Local File for 2024 – are approaching...
Master File (group transfer pricing documentation) – what is it and who is required to prepare it?
For many taxpayers, transfer pricing (TP) compliance forms a crucial part of their annual tax closing...
Repeated services provided by a partner in Estonian CIT
The tax authorities have changed their position on the so-called repeated non-monetary services provided...
Dividends and interest from abroad – another favourable ruling by the Supreme Administrative Court
On 24 June 2025, the Supreme Administrative Court (SAC) once again questioned the tax authorities’...
CBAM: what will change? Overview of upcoming changes for importers
On 1 January 2026, the transitional period for the CBAM (Carbon Border Adjustment Mechanism) will come...
Intra-group settlements under scrutiny by the CJEU - what does the Weatherford ruling mean for intra-group service acquisitions?
In the first article of our TP & VAT series (link: https://www.mddp.pl/intra-group-settlements-under-the-scrutiny-of-the-cjeu/...
Draft KSeF Act Adopted by the Council of Ministers – what concerns remained?
KSeF – the Final Stage of the Legislative Process On 17 June 2025, the Council of Ministers adopted the...
Crypto transaction reporting from 2026 – what should crypto-asset service providers know about DAC8?
Starting in 2026, new regulations on the automatic exchange of information regarding crypto-asset transactions...
Dividends in kind in Estonian CIT
Lump-sum tax on corporate income [Estonian CIT], as a very attractive form of taxation for individuals,...
Does having family in Poland determine your tax residency?
Many taxpayers living and working abroad ask themselves: does the mere fact that my family resides in...
Does a gratuitous guarantee under Estonian CIT mean no transfer pricing obligations?
Does a gratuitous guarantee granted to a taxpayer subject to Estonian CIT by a related entity give rise...
General partnership and transfer pricing in 2025 – Local file documentation, CIT-15J and TP obligations
The arm’s length principle applies to all entities conducting transactions with related parties...
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