In the previous material (The program of preferential loans for companies supporting Ukraine has been launched), we described in detail the principles of the program and the conditions that entrepreneurs must meet in order to take advantage of the support offered. Today, we return to the topic to take a look at what the implementation […]
A program of preferential loans for companies supporting Ukraine has been launched
Tetiana Startseva
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Polish companies can already apply for preferential loans under the Ukraine Facility mechanism. The preferential loan program is an opportunity for financial support for entrepreneurs interested in participating in the reconstruction and development of Ukraine’s infrastructure. Details are presented in today’s material. Who grants loans Bank Gospodarstwa Krajowego (BGK) plays a key role in organising […]
Latest Explanations from the Ministry of Finance on the ‘Beneficial Owner’: Key Insights
Tomasz Napierała
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On 3 July 2025, the Ministry of Finance issued tax clarifications on applying the Beneficial Owner (BO) clause for withholding tax (WHT) purposes. This document is of crucial importance for entities paying dividends, interest or royalties to foreign recipients. Definition of the beneficial owner For clarity, under the Polish law a Beneficial Owner is […]
Phantom stock option plans – a tax-efficient way to reward key employees
Marta Coda
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Companies wishing to reward their key personnel (management, employees or associates) for their achievements and build long-term relationships with them are increasingly introducing different incentive programmes. One interesting solution is a program based on phantom shares, which also offer tax benefits. What are phantom stock option plans? Phantom shares are derivative financial instruments that grant […]
Mandatory e-Invoicing from 2026
Elżbieta Skurczak
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In April 2025, the Polish government released another draft law regarding the rollout of mandatory electronic invoicing. As a rule, B2B invoices will have to be issued through a central platform called the National Electronic Invoice System (referred to as: KSeF). All VAT taxpayers with a seat or a fixed establishment in Poland will […]
Guarantee without remuneration – a transfer pricing perspective
Natalia Chwała
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Intra-group guarantees can significantly facilitate obtaining external debt financing or entering into contracts. This instrument is widely used but still raises questions relating to the transfer pricing. Can a guarantee be provided free of charge? According to the 2020 OECD Guidelines on Transfer Pricing for Financial Transactions, it is not justified in every case […]
Withholding Tax on Dividends – Recent Polish Developments
Tomasz Napierała
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Recent months have brought a number of important developments in Polish case law and tax authority interpretations concerning withholding tax (WHT) on dividends. While some rulings offer hope for a more taxpayer-friendly approach, inconsistencies and ongoing uncertainty continue to pose significant challenges. Below, we highlight key issues and recent decisions that impact cross-border payments from […]