Transfer Pricing: who has documentation and reporting obligations? If: you are a taxable person (subject to corporate income tax or personal income tax), and in 2023, you engaged in transactions with related parties, and the value of these transactions exceeded the statutory thresholds in 2023, then you need to determine your transfer pricing obligations…
Not long ago, we informed about an unfavourable stance of the Director of the National Fiscal Information (KIS) on the rules of taxation of beneficiaries of a foundation established jointly by members of the closest family (e.g. spouses). The Director of KIS has a modified approach to the manner of determining the proportion of property…
There is an ongoing wait for the new definitions of building and structure for property tax purposes to come into effect from 2025, which is just a few months away. One group of taxpayers for whom the announced regulations will be relevant are owners of various types of tent structures, such as tent covers, inflatable…
Aim of the SME package: simplify cross-border VAT settlements Currently, traders doing business in different European Union (EU) countries where they are not established must, in many cases, register for VAT. This requirement involves filing VAT returns in each EU country where VAT is due. This process is particularly burdensome for small and medium-sized enterprises…
Supreme Administrative Court draws attention to the economic nature of land sale transactions The Supreme Administrative Court (NSA), in a ruling of 23 August 2024 (ref. I FSK 1670/20), again addressed the issue of the application of the VAT exemption to the sale of undeveloped land. The ruling is in line with previous judgments of…
Transfer Pricing: obligations await! The holidays are coming to an end, and as children head back to school, businesses must also turn their attention to fulfilling transfer pricing obligations for the 2023 tax year. Key deadlines are approaching for: Local transfer pricing documentation (Local File) Transfer pricing information (TPR) Group transfer pricing documentation (Master File)…
Transfer prices can impact the amount of income taxed in different countries. To ensure compliance, set these prices at the same level that unrelated parties would use in their transactions. Here’s how to do it. Various transfer pricing verification methods are used to assess the prices set between related parties. There are five basic methods,…
On July 25, 2024, the Director of the National Tax Information issued an individual tax ruling[1] confirming the right to recognize a fee for the termination of a real estate sales contract as a tax deductible cost. What was the case about? In the case under review, a real estate development company entered into a…
What is a benefit test? The benefit test is an analysis that confirms the following: the purchased intangible services have indeed been performed, the recipient derives benefits from the purchase that contribute to their income, the purchase of services is business rational. Who does it apply to? The benefit test applies to all group entities…
The current position of the tax authorities confirms that people immigrating to Poland permanently who do not have a Pole’s Card on the date of their move – either because they have not applied for it before or have already obtained a permanent residence permit – cannot benefit from the PIT exemption. The exemption known…