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…
How to determine the place of supply of a service? The range of activities subject to VAT includes not only the sale of goods in exchange for consideration but also the supply of services in exchange for consideration within the country. While supplying services between Polish taxpayers usually does not pose many issues, expanding the…
The CJEU has once again clarified how to qualify new electromobility-related transactions on the basis of rather general and somewhat old tax rules. Again it was confirmed that the supply of electricity for the purposes of charging an electric vehicle at a charging point forming part of a public network of such points constitutes a…
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…
As a rule, the tax year for minimum tax is the calendar year. The legislation also allows taxpayers to amend this period depending on the decision expressed, inter alia, in the company’s articles of association. However, even in this situation, the tax year generally comprises twelve consecutive calendar months. In certain circumstances, this period may…
On October 4, 2024, the Court of Justice of the European Union (CJEU) delivered a judgment in the Voestalpine Giesserei Linz case (C-475/23), addressing the right to deduct VAT related to the acquisition of a machine provided free of charge to a subcontractor under a tooling agreement. The judgment pertains to a common practice, especially…
In a tax ruling dated 16 September 2024, ref. 0111-KDIB1-2.4010.340.2024.1.BD, it has been ruled that the income of a family foundation from the sale of cryptocurrencies is not exempt from corporate income tax but is taxed at a corporate income tax rate of 25%. Story A family foundation wanted to invest its assets in cryptocurrencies.The…
The deadlines for meeting transfer pricing obligations for 2023 are fast approaching, especially for taxpayers whose fiscal year aligns with the calendar year: by October 31, local transfer pricing documentation must be prepared. by November 30, transfer pricing information must be submitted using form TPR-C. In this post, we address common questions surrounding the submission…
On 5 October, the Act of 1 October 2024 amending the Act on special solutions related to flood recovery and certain other acts [Amendment Act] entered into force. Donations for flood relief with no impact on minimum income tax Newly introduced article 1(25) of the Amendment Act provides that for the purposes of calculating the…