MDDP Insight

MDDP Insight

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Transfer pricing
VAT
Benefit test: a global priority for tax authorities in transfer pricing
What is a benefit test? The benefit test is an analysis that confirms the following: the purchased intangible...
Do you hold a permanent residence permit? This could deprive you of return relief
The current position of the tax authorities confirms that people immigrating to Poland permanently who...
Intra-group funding: financial transactions are under scrutiny
Authorities around the world are increasingly scrutinizing the nature of intra-group loans We observe...
Operator to help settle VAT on deposit refund system (DRS)
At the end of July, a further version of the draft amendment to the DRS legislation also addressed tax...
Universal benchmarking - local and global transfer pricing perspective
International groups often prepare global benchmarks, which are used by entities in different jurisdictions...
Transfer of innovative business in international settlements: key global transfer pricing aspects
Increasing globalization is connected with not only threats but also with numerous opportunities. Multinational...
Changes in property tax 2025 and investments in RES
1. Is it true that the draft envisages taxing photovoltaic farms on all components, including PV panels? Not...
Compensation for energy-intensive sectors - first Supreme Administrative Court ruling for CIT taxpayers
After a series of favorable rulings for CIT taxpayers by provincial administrative courts in cases concerning...
Changes in property tax (PON) 2025: Issues important to developers
1. How will transformer stations be treated in the draft regulatory changes? Will they have to be taxed...
VAT group and neutrality of turnover within group - is this (finally) the end of the doubts?
Another German VAT group question The CJEU judgment of 11.7.2024 in case C-184/23 is another judgment...
Restructuring unveiled: a global take on restructuring from TP perspective
International groups often undergo business restructuring. If done between related parties, it must comply...
Changes in property tax 2025: definition of structure and building and other key issues
Should it be inferred from the draft that the concept of a structure takes precedence over the definition...
Transfer pricing can help grow your business internationally
The latest edition of Santander Trade Barometer reveals that nearly a third (28%) of UK domestic businesses...
VAT in the catering industry - an important Supreme Administrative Court resolution
8% or 5% VAT rate in catering? On Monday 24 June this year the Supreme Administrative Court (NSA) passed...
Assignment of rights under development agreement with 23% VAT
On 24 June 2024, the Supreme Administrative Court (hereinafter: NSA), in a judgment by seven judges [1],...
Transfer pricing adjustments: global challenge, national responsibilities
Transfer pricing adjustments (TP adjustments) are a complex and wide-ranging topic and their correct...
International settlement - global and local perspective of TP - what to keep in mind?
The main principle of the game is the same International groups can manage the topic of transfer pricing...
Heating up the dispute over VAT on illegal consumption of energy
Although it has been the accepted position in Poland for many years that illegal consumption  of energy...
Early contract termination not always subject to VAT
In a judgment of 17 May 2024 (ref. I FSK 1240/20), the Supreme Administrative Court (NSA) ruled that...
The new release of the ViDA project and an invoice in a specific format as a substantive condition for input VAT deduction?
ViDA – status of the project The negotiations on the EU package referred to as ViDA (VAT in the...
Transfer pricing across borders: our international solutions
Transfer pricing is (primarily) an international issue. Why? Because business is international. These...
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