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 […]

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 […]