Dedicated Transfer Pricing trainings What TP areas are you interested in? – QUESTIONNAIRE ASK ABOUT TRAINING We organize special trainings (both in-person and on-line) tailored to your needs. The workshops are hosted by our experts in TP matters who have expertise...

Important decision of the Supreme Administrative Court on large zone companies Large SEZ entrepreneurs operating on the basis of a so-called converted old permit can account for state aid until 2026 On 19 July 2022, a judgment was issued by the Supreme Administrative Court (Naczelny...

Poland gets green light for mandatory e-invoicing from 2024 The derogation is granted for three years, until December 31 2026. It may be extended further, but Poland will still need to prove that this tool led to reducing VAT fraud and abus as well as simplifying VAT settlement for...

The National Revenue Administration (KAS) has released the latest statistical data on APAs. Briefly: in Q1 2022, only 14 advance pricing agreements were made (all of them unilateral). Although a record was broken in 2021 for the number of agreements made (101), the data for Q1 2022...

TP documentation obligations: more than Local File and TPR or the Master File explained. For many taxpayers transfer pricing is only about compiling Local File or filling in the TPR form. From 2022, the so-called indirect tax haven transactions also trigger some obligations. There...

Higher remuneration for PIT remitters from July 1, 2022 From July 1, 2022, the rate of remuneration for some remitters of PIT tax advances has been increased twice. This results from the entry into force of the Ministry of Finance’s new regulation, issued on the basis of the provisions...

4 New Partners at MDDP Effective 1 July 2022, 4 new persons joined the partners of MDDP Michalik Dłuska Dziedzic i Partnerzy. Magdalena Jaworska became a partner in the VAT practice, Łukasz Kupień and Piotr Paśko in the Real Estate practice, and Agnieszka Krzyżaniak in the...

Yesterday, a draft amendment to the CIT Act was published on the website of the Government Legislation Center. It seeks to simplify and adapt to the current economic situation the provisions introduced as part of the Polish Deal. The draft introduces regulations previously announced...

Not every adjustment to transaction prices is a transfer pricing adjustment Related parties often apply transaction price adjustments in their settlements. The so-called contractual adjustment and transfer pricing adjustment within the meaning of Article 11e of the CIT Act are perceived...

New tool for electronic communication with tax authorities – the e-Tax Office On 7 July 2022, the Act amending certain acts in order to automate the handling of issues by the National Revenue Administration (KAS) is to come into force. The new regulations are intended to automate...

In recent days, Artur Soboń – Deputy Minister of Finance – announced changes in CIT aimed at simplifications and solutions aligned with the current economic situation. The Ministry of Finance proposes simplified rules concerning the documentation of tax haven transactions and increasing...

Polish Deal [Polski Ład] 2.0 – changes in PIT, ZUS social security insurance and NFZ National Healhcare Funds as of 1st July 2022 Amended provisions of the so-called “Polish Deal” have been published in the Journal of Laws. Some of the changes enter into force already on 1st...

MDDP on Polish Taxes I VAT Groups June 22, 2022 at 10:00 a.m.June 22, 2022 | 10:00 a.m.: Register In 2023, VAT taxpayers (and branches of foreign taxpayers) will have the opportunity to form a VAT Group, allowing a group of entities to be treated as a single VAT taxpayer. As a result,...

Today we wish to remind you of how important it is to properly determine the functional profile for TP purposes. The functional profile results from the entity’s involvement in the transaction: the functions performed, the assets involved and the level of risk exposure. Importantly,...

MDDP on Polish Taxes I Tax on shifted income, including financing costs and taxation of hidden dividends June 8, 2022 at 10:00 a.m. Polish legislator often uses the carrot and stick approach. However, when it comes to financing costs, stick policy prevails. Each and every year, new...