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 […]

Tax relief for robotization – a chance for tax benefits

Tomasz Napierała

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From 2022, Polish entrepreneurs can take advantage of the robotization relief – a solution that is intended to encourage the automation of processes (e.g. in production or logistics) and increase the attractiveness of enterprises on the domestic and foreign markets. We remind you what this preference is and what doubts it raises.   What is […]

Taxes in Poland: what lies ahead in 2026?

Elżbieta Skurczak

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The year 2026 is less about brand-new tax rules and more about a massive shift in how businesses report data to the government. The focus is on digital compliance – moving from paper and PDFs to real-time data sharing with tax authorities.   Mandatory e-invoicing (KSeF) The National e-Invoicing System (KSeF) is finally becoming a […]

Licence Fee – How to Determine Arm’s Length Remuneration

Natalia Chwała

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Transactions involving intangible assets, such as trademarks, patents, know-how or licences, are at the centre of interest of tax authorities. In tax practice, they constitute one of the areas with increased transfer pricing risk. This results from the difficulty in valuing such assets and from the fact that they are often used in transactions between […]

Bite-size VAT updates

Elżbieta Skurczak

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KSeF: Transition to Version 2.0 Confirmed Poland’s Ministry of Finance officially confirmed the final transition roadmap for the National e-Invoicing System (KSeF) to version 2.0, with the mandatory start date remaining February 1, 2026 for large taxpayers and April 1, 2026 for all other taxpayers. In September 2025, the older KSeF 1.0 test environment was […]

Actions Against Aggressive Tax Optimization – Transfer Pricing

Natalia Chwała

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The Ministry of Finance is intensifying its efforts against aggressive tax avoidance and the shifting of profits abroad. During a press briefing on July 31, 2025, the Minister of Finance and Economy, Andrzej Domański, together with the Head of the National Revenue Administration (KAS), Marcin Łoboda, presented the achievements to date as well as new […]

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