Master File – what it is and who it applies to

Master File – what it is and who it applies to

For taxpayers subject to transfer pricing compliance obligations, October and November tend to be particularly intensive months. Preparing documentation, gathering the necessary information, and submitting TPR forms undoubtedly require considerable time and attention. However, there is one further important obligation that should not be overlooked. We invite you to read our article, where we provide…

General tax ruling regarding withholding tax matters – breakthrough or continuation of past practice? – part I – dividends

In recent days, the Ministry of Finance has published two general rulings relating to some of the conditions for the exemption from withholding tax of dividend and interest payments. These rulings are important, but are they groundbreaking? How will the existing practice of the authorities and courts change? In the first part, we are going…

The performance of a Polish permanent establishment of a foreign company may be relevant for the national minimum tax

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…