Charging an electric vehicle at a network of charging points to which the user has access on the basis of a subscription contracted with a company other than the operator of the charging point means that the electricity consumed is supplied to users by that operator and the company offering access to those charging points…
When distinguishing between single-purpose vouchers (so-called SPVs) and multi-purpose vouchers (so-called MPVs), it is necessary to examine whether, at the time of issue, the place of supply of the transaction to the final consumers to which the voucher relates and the amount of VAT due thereon are already known. The fact that final consumers may…
Financial transactions are one of the most common transactions between related parties and also most frequently controlled by the tax authorities. Due to the an extensive catalogue of financial transactions and their level of complexity, taxpayers often face problems in justifying the arm’s length nature of these transactions. In addition, the unfavourable approach to taxpayers…
Judgment of the Voivodship Administrative Court in Warsaw of April 18, 2024, ref. III SA/Wa 8/24 It would seem that the topic of the importance of the acceptance protocol for determining the moment when VAT liability arises for the provision of a service is quite clear and straightforward, as it has often been the subject…
With each passing year, courts increasingly confirm that a properly prepared benchmarking study can be an extremely important tool, both for taxpayers and tax authorities. Tax authorities often challenge benchmarking study by either conducting new analyses or modifying those presented by taxpayers. This frequently leads to increased tax liabilities. Therefore, having a reliable transfer pricing…
Following the meeting of the VAT EXPERT GROUP in Brussels on 18 March, the next steps for VAT in the digital age are becoming much clearer. The group, made up of specialised VAT experts, plays a key role in providing information and opinions on the practicalities of implementing EU tax regulations. Three weeks after this…
Price adjustments are still not a clear-cut issue and raise questions for taxpayers. In 2023, administrative courts issued rulings on adjustments in three main areas described below. Definition of transfer pricing adjustments It is worth recalling that TP adjustments refer to transactions between related parties and are an important part of business practice. However, their…
Intra-group loan Intra-group loans, like other related party transactions, should be made on an arm’s length basis. In order to verify loan transactions to comply with the arm’s length principle, the comparable uncontrolled price method is most often used in the external variant. Data for this analysis is obtained from external specialized databases. Tax authorities…
In the dynamic business world, planning of settlement between related parties is becoming an essential part of groups’ business strategy. Changes in the market affect the development of new technologies, products and services. They determine the activities of companies in achieving economic benefits and competitive advantages. Well planned settlements are the basis for business success,…
One thing is certain: there is no turning back from National e-Invoice System [hereinafter: KSeF]. This was confirmed by the Minister of Finance, Andrzej Domanski, on 21 March 2024 at a meeting where representatives of the ministry summarised the consultation cycle on KSeF and outlined the planned changes to the legislation already enacted. We undoubtedly…