Simplified mergers are now clearly neutral for CIT purposes Amendment to the CIT Act within the framework of Energy Law changes On August 5, 2025, the Act amending the Energy Law and certain other acts clarified the Corporate Income Tax (CIT) regulations regarding mergers conducted...

The e-Invoicing Act (“KSeF 2.0”) published in the Journal of Laws The Act of August 5, 2025, amending the VAT Act and the so-called Act on the National e- Invoicing System (KSeF), introducing mandatory KSeF, was published on September 1, 2025, in the Journal of Laws of the Republic...

Transfer pricing back in the spotlight. New presidential initiative could mean more audits A change in the Presidential Palace often signals a shift in economic and tax policy. This time, alongside the widely publicised proposal to introduce tax relief for families raising at least...

Ministry of Finance announces changes in the taxation of family foundations from 2026 On 8 August 2025, representatives from the Ministry of Finance and the Ministry of Economy announced an increase in the taxation of family foundations. According to the Ministry’s declarations,...

GloBE – automatic exchange of information – first signatories of the multilateral agreement (GIR-MCAA) and other tools for handling GloBE. On 6 August 2024, a list of 14 signatories to the multilateral agreement on information exchange GloBE (GIR-MCAA, GloBE Information Return-Multilateral...

Work on draft Unshell Directive on hold – member states prefer DAC6 changes The Unshell Directive (ATAD3) is about companies without significant activities. It was intended to set an EU standard for the minimum substance of companies to prevent tax avoidance. The DAC 6 in the...

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...