WHT Explanatory Notes from 3rd July, 2025 on the application of the so-called beneficial owner clause for withholding tax purposes On July 9th; 2025 the long-awaited WHT Explanatory Notes regarding the application of the so-called beneficial owner clause for withholding tax purposes...

Extension of tax exemption for foreign investment funds The Ministry of Finance has published a draft amendment to the Corporate Income Tax (CIT) Act, responding to key judgements of the Court of Justice of the European Union (CJEU). The proposed regulations aim to eliminate the inconsistencies...

Landmark CJEU ruling on railway sidings and, more broadly, state aid in the context of taxation On 29 April 2025, the Court of Justice of the European Union in Luxembourg issued a ruling favourable to taxpayers in case C-453/23 concerning the Mayor of Mielec. This is the first CJEU...

Management board liability – another important CJEU judgment On 30 April, the Court of Justice of the European Union (CJEU) issued a significant judgment concerning the Polish regulations governing joint and several liability of management board members for a company’s tax...

GloBE: Latest proposals from the Ministry of Finance on the shape of the R&D tax relief On 9 April, a meeting was held with representatives of the Income Tax Department of the Ministry of Finance. The purpose of the meeting was to discuss two scenarios (A and B) for changes to...

“Stop-the-Clock”: Postponement of CSRD and CSDDD implementation timelines On 3 April 2025, the European Parliament voted in favour of postponing the implementation timelines of the CSRD (Corporate Sustainability Reporting Directive) and the CSDDD (Corporate Sustainability...

A marriage may be regarded as a VAT taxpayer! – Groundbreaking CJEU ruling in Case C-213/24, Grzera On 3rd April 2025, the CJEU delivered a highly significant judgment in the Polish Case C-213/24, Grzera. The ruling concerns, firstly, whether a seller can be considered a VAT taxpayer...

Landmark judgement of the CJEU reshapes Polish tax exemption for investment funds The Court of Justice of the European Union (CJEU) issued a judgement (Case C-18/23) on February 27, 2025, declaring that Polish requirements limiting CIT exemption to externally managed funds are in...

Revolutionary judgment by the CJEU on provisions on joint and several liability of management board members The Court of Justice of the European Union (CJEU) today issued a landmark judgment (Case C-277/24 Adjak) challenging the model adopted in Poland of joint and several liability...

The obligation to integrate payment terminals with cash registers is repealed and other VAT changes from April 1, 2025 We present the most important changes in VAT and cash registers regulations introduced by the Act of January 24, 2025, amending the Act on Value Added Tax, the Act...

Last days to change the tax form and choose the cash-based PIT in 2025 – the deadline is February 20   Until February 20 (Thursday), it is possible to submit a declaration regarding the choice of the income tax form. Individuals conducting a sole proprietorship and partners in selected...

From 1 April 2025, e-Delivery will be mandatory for all entrepreneurs entered in the Polish register of entrepreneurs (KRS) From 1 April 2025, all entities registered in the Polish register of entrepreneurs (KRS) will be required to use e-Delivery in correspondence with public authorities. Each...

Deferred Tax Year – transfer pricing deadlines alert Transfer pricing deadlines are calculated from the end of the tax year. For instance, if your tax year ends March 31, 2024, the TPR form must be submitted by February 2025 (within eleven months). Key transfer pricing deadlines  All...

Don’t financial transactions disrupt VAT deduction in your company? The correctness of calculating the so-called VAT coefficient is a headache for many accountants. Especially entities that do not perform financial transactions on a daily basis may not even realize that transactions...

Tax changes 2025 The beginning of 2025 ushered in substantial revisions to the Polish tax system. Numerous regulations have taken effect, significantly impacting tax settlements. The key changes are outlined below.   JPK_CIT Effective January 1, 2025, the CIT Act mandates the digitalization...