Company tax residence – actual management abroad and country of taxation
Remote working and international management structures lead to situations where companies registered in Poland are actually managed from another country – e.g. by members of the management board residing in Germany, the Netherlands or Austria. This situation can have very serious tax consequences. In particular, it may lead to a... Read More →
Transfer pricing in the spotlight of the tax authorities – a growing risk for companies in Poland
The tax authorities are gradually moving from spot checks to systematic supervision of taxpayers’ settlements, focusing on areas that may lead to understatement of income or transfer of profits outside Poland. The increase in the value of income reassessments and the development of analytical tools such as JPK_CIT and KSeF... Read More →
Transfer pricing adjustments may be subject to VAT – CJEU judgment in Arcomet (C-726/23)
In its judgment of 4 September 2025 in Arcomet Towercranes (C-726/23), the Court of Justice of the European Union took a position on intra-group settlements between related companies. The CJEU ruled that the equalisation of operating margins between entities within the same group may constitute a supply of services for... Read More →
IP BOX relief and subcontractors in Poland – Supreme Administrative Court ruling
Does a company that designs solutions and manages work on a system, but outsources coding to a B2B programmer, still conduct R&D activities – and is it entitled to a 5% IP Box relief – preferential PIT and CIT taxation of income from eligible intellectual property rights (e.g. copyrighted computer... Read More →
Tax audits in the first half of 2025 – fewer actions, greater effectiveness
According to data from the Ministry of Finance, 4,271 tax audits were initiated in the first half of 2025, which represents a decrease of 16.4% compared to the same period in 2024, when there were 5,108 audits. At the same time, 3,979 tax audits were completed, which is 25.6% less... Read More →
Withholding tax and foreign income in Poland – the Supreme Administrative Court decides how to calculate the withholding tax deduction limit
In its judgment of 28 May 2025 (II FSK 1131/22), confirmed that when settling withholding tax (WHT) paid abroad in Poland, the deduction limit under Article 20(1) of the CIT Act refers to income earned in a foreign country, not to revenue. The ruling was made in a case involving... Read More →
Customs value and final price – CJEU position: transaction value is determinative
In case C-782/23 (Tauritus), the Court of Justice of the European Union ruled that the customs value of imported goods should be determined primarily using the transaction value method, even if only a provisional price is known at the time of customs declaration. It is crucial that the mechanism for... Read More →
Cryptocurrency tax in Poland in 2025 – rules and settlement
The settlement of cryptocurrencies in Poland is regulated by the provisions of the Personal Income Tax Act (PIT). Since 2019, a clear tax classification has been introduced – trading in virtual currencies is treated as a sale of virtual currency (property rights) for consideration. Income from trading in cryptocurrencies is... Read More →
Changes in the employment of foreigners in Poland: employer obligations, employees from Georgia and the new Ministry of Family, Labour and Social Policy regulation
New obligation towards foreigners: information on the right to trade unions From 1 June 2025, a new provision of the Act on the conditions for admitting foreigners in Poland to employment will come into force, according to which employers will be required to inform foreigners in writing of their right... Read More →
Dividend tax in Poland – regulations, rates and practical aspects
Dividend tax in Poland is a special type of withholding tax (WHT) collected at the time of payment of profits by a company to its partners or shareholders. There is no separate tax exclusively for dividends – they are treated as taxable capital income. In practice, this means that both... Read More →
