When does a cost adjustment become a transfer pricing adjustment?

Natalia Chwała

0

Many international groups calculate service fees during the year using budgeted or historical costs and adjust the amounts once the actual costs are known. This is a common approach where the final remuneration is determined under the cost plus method. The practical question is whether such a year-end true-up is only a standard cost adjustment […]

Tax schemes from 1 October 2026: the end of domestic tax scheme reporting

Elżbieta Skurczak

0

Significant changes to the tax scheme reporting rules took effect on 1 October 2026. The Polish legislator decided to substantially reduce the scope of reporting obligations and bring the Polish regulations closer to the standard established by the EU DAC6 Directive. For businesses, the most tangible change will be the complete abolition of the obligation […]

Dividends – withholding tax – Polish tax authorities trying to introduce “effective taxation” requirement

Tomasz Napierała

0

In recent years, disputes regarding withholding tax (WHT) on dividends have focused mainly on the status of beneficial owner, real business activity or the artificiality of holding structures. Currently, however, we are observing another direction of argumentation of the Polish tax authorities. More and more often, the authorities are trying to make the possibility of […]

Return relief for individuals returning to Poland

Aleksandra Ulążka

0

The so-called return relief, introduced as part of the Polish Deal, provides a PIT exemption for individuals who have lived and worked abroad and decided to return to Poland. The exemption is available only if certain conditions are met and applies up to PLN 85,528. To benefit from the relief, taxpayers need to properly assess […]

VAT reform: service buyers could be held liable for a supplier’s unpaid VAT

Elżbieta Skurczak

0

For years, joint liability in Polish VAT has been associated primarily with transactions involving so-called “sensitive goods”. Businesses purchasing fuel, steel products or other items listed in Appendix 15 to the VAT Act have become accustomed to exercising enhanced caution when selecting suppliers. However, the Ministry of Finance is now proposing a significant expansion of […]

Polish Investment Zone reform: tax relief may become easier to use

Tomasz Napierała

0

Poland is planning significant changes to the Polish Investment Zone (PIZ) regime, one of the key tax incentives available to companies investing in Poland. The PIZ allows companies carrying out new investments in Poland to benefit from income tax exemption. In practice, it may significantly reduce the effective tax burden on profits generated from eligible […]

Master File from the Parent Company Is Not Everything. What Should a Polish Taxpayer Verify?

Natalia Chwała

0

When is a Master File required? Group transfer pricing documentation (Master File) constitutes one of the elements of transfer pricing documentation. In practice, it is most often a separate document, typically rather extensive, prepared by the headquarters of the corporate group. The Master File contains key information on the entire group of related entities, including, […]

WHT refund obtained? Interest may also be recoverable

Weronika Sydow

0

If a Polish company has obtained a refund of withholding tax (WHT) under the Polish pay-and-refund regime, it may also be possible to recover the late-payment interest paid together with that tax. This position has recently been confirmed by the Polish courts. Recovering WHT is not always the end of the story Since 2022, Poland […]

Transfer Pricing: Key Considerations for Business Restructuring

Natalia Chwała

0

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

0

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 […]