Transfer pricing in Poland in 2026: schemas, forms and reporting changes
In 2026, transfer pricing remains one of the most demanding areas of Polish tax compliance. What matters more than ever is the quality and consistency of financial data reported in the Transfer Pricing Information form (TPR), Country-by-Country Reporting (CbC) and public CbC reporting (PCbCR) — and how well those figures... Read More →
Country-by-Country reporting in 2026 – filing requirements for CbC-P notification and CbC-R report
According to OECD regulations on tax information exchange, multinational corporate groups are required to report their organizational structures and financial results. The purpose of this obligation is to ensure greater tax transparency and to limit aggressive tax optimization practices. What is CbC Reporting? The primary goal of Country-by-Country (CbC) reporting... Read More →
Fixed establishment (FE) for National e-Invoicing System (KSeF) in Poland – MoF guidance of 28 January 2026 and practical implications for businesses
A fixed establishment (FE) is a VAT concept describing a situation where a taxpayer — despite having no registered office in Poland — has a sufficiently stable and organised presence in Poland (people and technical resources) that can genuinely take part in transactions. In Polish tax guidance, this concept is... Read More →
Returning to Poland: tax settlement in the relocation year and taxation of foreign income – a complete guide for those returning from emigration (Part 4)
A return to Poland (especially after a longer break, e.g., returning to Poland after 10 years abroad) usually means a shift in your legal and tax environment: different forms, different deadlines — and, most importantly — different rules for determining where and to what extent you must settle your income.... Read More →
Withholding tax (WHT) in Poland: WH-OSC statements should not be filed too early
Withholding tax (WHT) remains one of the most sensitive areas of tax compliance in cross-border transactions under Polish tax law. Particular attention is required when applying the pay and refund mechanism, which – once a statutory payment threshold is exceeded – generally obliges the payer to withhold tax at the... Read More →
Combined Nomenclature 2026 (CN) – what’s changing and how it impacts businesses in Poland
From 1 January 2026, businesses must apply the updated Combined Nomenclature (CN 2026) for goods classification in the EU. For companies that import into Poland, export from Poland, or report intra-EU movements, this is not just a customs update. CN codes are part of your product master data and appear... Read More →
Higher penalties for fiscal misdemeanours and fiscal crimes from 1 January 2026 – a real risk for businesses in Poland
Tax penalties in Poland 2026 have increased significantly as of 1 January 2026. With the start of the year, important changes took effect that materially tighten taxpayer liability — especially for entrepreneurs and companies — for breaches of Polish tax rules. Even though there has been no formal amendment to... Read More →
EUDR Regulation postponed – what does the deferral mean for businesses?
The EUDR Regulation – the EU’s anti-deforestation regulation – has once again been postponed. Originally scheduled to come into effect on 30 December 2025, the deadline has been extended by EU institutions for another year. The EUDR Regulation will now apply as of 30 December 2026, while micro and small... Read More →
Returning to Poland: how to determine tax residency and avoid double taxation – a complete guide for those returning from emigration (Part 2)
Returning to Poland from emigration is a decision that brings not only emotional and life changes, but also very specific tax consequences. For many people returning from Germany, the United Kingdom or other EU countries, tax residence and the risk of double taxation become key issues. In this part of... Read More →
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 →
