Magdalena Zamoyska and Monika Grobelska of MDDP explain a series of amendments for 2023 that are expected to improve the accessibility and functioning of the Polish holding company model. A capital gains tax participation exemption for holding companies was introduced into Polish...

The amendment to the Polish Deal, which has recently come into force, has brought favourable changes for taxpayers in the area of transfer pricing. The provisions introduced consist in changes in the area of transactions with tax havens, including, most notably, the repeal of controversial...

The Polish Holding Company (PHC) is a solution that has been effective in the CIT Act since 1 January, 2022 and is intended to encourage investors to invest through Polish holding companies in other entities. In principle, the PHC allows for an exemption from taxation of dividend...

On 8 November 2022[1], the Court of Justice of the European Union (‘the CJEU’) annulled the decision of the European Commission and the judgment of the EU Court, which recognized the individual ruling issued by the authorities in Luxembourg as providing a ‘selective advantage’ to...

Green taxes in the fight against climate change There is a perception that the only meaningful achievement of this year’s COP27 summit is the agreement to set up a ‘loss and damage’ fund to cover the losses of developing countries caused by climate change-related disasters. Beyond...

Autumn has come and it has been followed by another changes in tax regulations, including the flat-rate income tax, or so-called withholding tax. Background to the changes The current version of the withholding tax regulations came into force on 1 January 2022. However, the fact that...

Transactions involving intangible assets are among related-party transactions causing the greatest difficulties for taxpayers when meeting their transfer pricing obligations. Taxpayers often find it challenging to prepare the valuation of intangible assets itself. They also need to...

MDDP on Polish Taxes I Supplies of excisable goods to Poland and from Poland in 2023 – most relevant changes February 2, 2023 at 10:00-11:00 a.m. CET February 2, 2023 at 10:00-11:00 a.m. CET: Register As of 13 February 2023, supplies of excisable goods are going to...

VAT rates and selected changes in excise duty rates in 2023 Please be advised that legal acts indicating which goods and services will still be subject to reduced VAT rates in 2023 have recently been published. The changes also applies to excise duty rates and exemptions from excise...

MDDP advised the owner of the Stokrotka brand on the acquisition of another chain of stores MDDP advised Emperia, the owner of the Stokrotka brand, on the acquisition of a chain of stores operating in the Mazowieckie Voivodeship. The list of Stokrotka stores increased by 13 new locations. The...

Some taxpayers currently compiling Local Files and TP-R forms for 2021 will not complete their struggle with transfer pricing on 31 December 31 (if their tax year matches the calendar year). They will face additional obligations related to Master File for 2021. What is Master File? The...

The most important change concerning the minimum tax is the exemption of taxpayers from this tax in 2022 and 2023. For taxpayers whose fiscal year is different from the calendar year and starts before 1 January 2024 and ends after 31 December 2023, the exemption will apply until the...

New MDDP office in Jablonowskich Palace As of mid-December, MDDP has been relocating. Our office is located in the restored Jabłonowski Palace at 18a Senatorska St. in Warsaw. It is no coincidence that we have chosen modern interiors located in a historic building for our new headquarters....

The reform of Estonian CIT (sometimes called as “lump sum taxation”) under the Polish Deal, which began in 2022, allowed for a significant expansion of access to this form of taxation, e.g. by expanding the catalogue of entities eligible to apply Estonian CIT, reducing the flat rate...

There is less than a month left to meet the transfer pricing reporting deadlines. One of the obligations is to file to the Polish tax office a statement on transfer pricing documentation and on the arm’s length nature of the transaction. The statement shall be signed by members of...