Tax residency certificate as a condition for applying a Double Taxation Agreement (DTA) to withholding tax (WHT) in Poland – Polish Supreme Administrative Court (NSA) ruling
A tax residency certificate is now a key document for Polish withholding tax (WHT) payers. It determines whether the preferences of a Double Taxation Agreement (DTA) can be applied or whether tax must be collected at the domestic rate. The judgment of the Supreme Administrative Court (NSA) of 20 August... Read More →
Taxation of a German tax resident serving as a member of the management board in a Polish company – Polish National Revenue Information Service (KIS) interpretation
The issue of taxation of a German resident who is a member of the management board of a Polish company is one of the most frequently raised issues in international capital groups. It concerns both Polish entities employing foreign managers and German entrepreneurs delegating employees to manage subsidiaries in Poland.... Read More →
Interest charged by the parent company as a tax-deductible expense of a Polish branch – Polish Supreme Administrative Court (NSA) ruling
The question of whether interest charged by a parent company can constitute a tax-deductible expense for a foreign company’s branch has long been a source of interpretative doubts and uncertainty among entrepreneurs and tax advisors. This makes the final judgment of the Supreme Administrative Court (NSA) of 30 July 2025... Read More →
Changes to the Tax Ordinance in Poland – new control rules and presumption of innocence in taxation
The changes to the Tax Ordinance, which came into force on 4 November 2025, significantly modify the relationship between taxpayers and tax inspection authorities. For the first time in years, the legislator has introduced regulations strengthening the position of entrepreneurs: both by limiting the length of audits and by introducing... Read More →
Returning to Poland: tax relief for returnees – a complete guide for those returning from emigration (Part 1)
Returning to Poland after years of emigration is a huge life change for many people. In addition to new family and professional challenges, there are also formal issues to deal with, including those related to taxes. One of the most important tools supporting people who decide to return to Poland... Read More →
A branch of a foreign company with the same tax identification number (NIP) as the parent company – confirmation in the interpretation of the National Tax Information Office (KIS) in Poland
The Director of National Tax Information Office (KIS), in an individual interpretation of 22 August 2025 (ref. 0111-KDIB3-2.4018.8.2024.10.MGO), confirmed that a branch of a foreign company may use the tax identification number (NIP) assigned to the parent company. This position was issued following the ruling of the Supreme Administrative Court... Read More →
A member of the management board may defend themselves against the Polish tax authorities – general interpretation by the Minister of Finance
A new general interpretation of the Polish Minister of Finance and Economy (DTS2.8012.5.2025) clarifies the rules for applying Article 116 of the Tax Ordinance following the CJEU judgments in the Adjak and Genzyński cases. Board members gain broader rights of defence – they may challenge the basis for the company’s... Read More →
EUDR Regulation – new obligations for companies in Poland from 30 December 2025
What is the EUDR Regulation and why is it so important? The EUDR Regulation (EU Deforestation Regulation, Regulation (EU) 2023/1115) is one of the most important EU tools in the fight against global deforestation and forest degradation. Its aim is to ensure that products placed on the EU market or... Read More →
Innovation reliefs – a comprehensive guide for entrepreneurs in Poland
Innovation reliefs are currently one of the key tools supporting the development and competitiveness of companies in Poland. They include a set of tax preferences designed to encourage entrepreneurs to invest in new technologies, products and solutions that improve their operations. These include, among others, tax relief for research and... Read More →
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 →
