MDDP Insight

MDDP Insight

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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...
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...
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