The Ministry apparently decided to dose up the excitement about the KSeF project and a week after the publication of the assumptions of the draft law amending the law introducing the compulsory KSeF in the list of legislative works of the Council of Ministers, a draft law with an explanatory memorandum was published on the…
A Polish branch of a foreign company that is a permanent establishment may be part of a group and benefit from a preferential tax rate on income from qualified intellectual property rights. 18 July 2022. The Director of the National Fiscal Information [KIS Director] issued an tax ruling[1] in which wase confirmed that a foreign…
As the year draws to a close, companies are preparing their final accounts for 2024. Now is the last opportunity to carefully review and make any necessary adjustments to settlements, pricing, or contract terms. The adjustments themselves continue to raise numerous interpretative questions, not only about their definition but also regarding the conditions for their…
Family foundation it is something that has not been known to Polish legal system until May 2023. As a family foundation is generally exempt from income tax, this exemption is the one that stirs up the most emotion. For this reason, potential founders or existing foundations seek to confirm the tax consequences in private letters…
On Monday 21 October 2024, the Supreme Administrative Court [hereinafter: NSA] adopted a resolution by a panel of seven judges (ref. III FPS 1/24) concerning the right of the Head of the National Tax Administration [hereinafter: KAS] to impose penalties on banks and other institutions obliged to submit reports within the STIR system. The NSA…
Since May 2024 this year, the Director of the National Tax Information has issued several individual tax rulings changing the hitherto relatively uniform line of interpretation of the look-through approach (LTA) in withholding tax. The LTA consists of disregarding the formal recipients of payments or intermediaries, attributing the tax consequences of the payment to the…
The local minimum income tax payable in 2025 will be calculated for the first time on the basis of the tax results achieved in 2024, and although there is still some time left before this deadline, taxpayers are already checking whether they will be subject to tax on the basis of historical data. One of…
Transfer pricing is essential for both businesses and tax authorities, as it involves setting prices for transactions between related parties, where there may be a risk of under-reporting income in one of the jurisdictions. For this reason, it’s important to ensure these prices are correctly determined, and then properly verified. In this post, we outline…
This is one of the key tools tax authorities use to verify transactions between related parties. With the TPR form deadline approaching, here’s a reminder of the essentials of transfer pricing reporting: What transfer pricing information is, What data it includes, Who is required to submit it, Who is liable for failure to submit, What…
Automation of tax processes using artificial intelligence (AI) is becoming increasingly common among businesses as well as tax authorities. Tax authorities are benefiting from the technological revolution From the perspective of tax authorities, AI first and foremost allows for more efficient analysis of the vast amounts of data received from taxpayers. This allows for faster…