Year: 2026

Transfer Pricing: Key Considerations for Business Restructuring

Natalia Chwała

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Business restructurings can have significant transfer pricing implications, particularly when they involve changes in functions, assets, or risks between related entities. This article outlines when a reorganization qualifies as restructuring and what documentation and reporting obligations may arise. For the purposes of transfer pricing regulations, not every business reorganization qualifies as a restructuring. At the […]

Polish regulations on the timing of VAT deduction are inconsistent with EU law – the landmark ruling of the EU General Court

Elżbieta Skurczak

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On February 11, 2026, the General Court of the European Union issued an important ruling in a Polish case that may have significant practical implications for Polish taxpayers. The case concerned the timing of the deduction of input VAT.   What was the dispute about? The dispute related to the provision of the Polish VAT […]

Poland Strengthens Labour Inspections: What International Groups Need to Know

Tomasz Napierała

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Major reform of the Polish Labour Inspectorate (PIP) signed into law On 2 April, the President of Poland signed a significant amendment to the Act on the National Labour Inspectorate (Państwowa Inspekcja Pracy – “PIP”), substantially expanding the powers of labour inspectors. At the same time, the law was referred to the Constitutional Tribunal for […]

Transfer tax residency to Poland – a proposal for wealthy non-residents

Tomasz Napierała

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Since 2022, regulations have been in force in Poland providing for very preferential rules for taxing foreign income for people who transfer their tax residence to Poland – the so-called lump sum on foreign income. This is a tax incentive for wealthy non-residents obtaining Polish tax residency.   Who can benefit? The lump sum taxation […]