Remote work from Poland and permanent establishment risk for foreign companies – Supreme Administrative Court of Poland (NSA) judgment
A permanent establishment in Poland is one of the key tax issues foreign companies should assess when hiring employees who work remotely from Poland. A judgment of 28 October 2025 issued by the Supreme Administrative Court of Poland (Naczelny Sąd Administracyjny, NSA) confirmed that an employee working from a private... Read More →
Contractual penalties and tax-deductible costs in Poland – a ruling by the Supreme Administrative Court of Poland (NSA)
Contractual penalties and tax-deductible costs in Poland are an important issue for businesses performing services, deliveries, construction projects and long-term contracts. The latest case law of the Supreme Administrative Court of Poland (NSA) confirms that not every contractual penalty is automatically excluded from tax-deductible costs. If a penalty is charged... Read More →
Seconding employees to Poland and PIT obligations
Seconding employees to Poland now requires a much broader analysis than simply checking how long an employee will stay in the country. For foreign companies and international groups, the key issue is not only where the employment contract was formally signed, but also who actually benefits from the employee’s work,... Read More →
Tax relief for returning to Poland: when the Polish tax office may challenge the PIT exemption
Tax relief for returning to Poland is attracting growing interest from people who, after several years of living and working abroad, move back to Poland. From the taxpayer’s perspective, it is a very specific preference: an exemption from Polish personal income tax (PIT) on qualifying income up to PLN 85,528... Read More →
Tax audits by Poland’s National Revenue Administration (KAS): how companies should prepare in 2026
Tax audits carried out by Poland’s National Revenue Administration (Krajowa Administracja Skarbowa, KAS) now look very different from how they did just a few years ago. They are becoming less broad and random, and increasingly precise, data-driven and based on risk assessment and digital reporting tools. For businesses, this marks... Read More →
VAT exemption for intra-Community supplies: what the CJEU ruling means for businesses in Poland
VAT exemption for intra-Community supplies is a key issue for businesses that sell goods to customers in other European Union Member States. The judgment of the Court of Justice of the European Union (CJEU) of 13 November 2025 in case C-639/24 FLO VENEER confirms that a tax authority cannot refuse... Read More →
Accounting books of foreign branches vs. JPK_CIT: what Polish tax authorities expect
Until recently, the accounting books of foreign branches were mainly associated with local reporting duties in the country where the branch operates and with feeding data into the Polish head office’s financial statements. With the introduction of structured reporting of accounting records under SAF-T for corporate income tax (JPK_CIT), the... Read More →
The National e-Invoicing System (KSeF) structured invoice for non-transaction transfers of own goods to an EU warehouse – is it required?
In Poland, the move to mandatory e-invoicing through the National e-Invoicing System (KSeF) is forcing businesses to revisit VAT scenarios that were previously treated as pure logistics. One of the most sensitive examples is the KSeF structured invoice for intra-Community transfers of own goods — i.e., moving your own stock... Read More →
Partner remuneration for managing the company as hidden profits in Estonian CIT in Poland
Hidden profits in Estonian CIT in Poland are becoming an increasingly practical risk area — especially where a company (or partnership taxed under the Estonian model) settles recurring benefits with its partners. An amending interpretation issued by the Head of the National Revenue Administration (KAS) on 7 November 2025 (ref.... Read More →
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 →
