This is a page for the tag Double Taxation Agreement (DTA)
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 →
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 →
Remote work (Home Office) does not exclude the creation of a permanent establishment for tax purposes
Nowadays, a flexible approach on working policies became one of the leading global trends on the job market. A growing number of employers have adopted the formula of remote work, more commonly referred to as: “home office”. This formula is also immensely popular among companies which recruit their employees abroad.... Read More →
Controlled Foreign Corporations (CFC) – more entities
Tax changes implemented as of January 1, 2022 expanded the catalog of entities qualifying as Controlled Foreign Corporations (CFC), thereby requiring more entities to apply tax rules specific to those entities. The most significant of these changes include: the addition of two new specific entity qualification categories, extension of the... Read More →
Polish Deal – Changes applicable to Polish Personal Income Tax (PIT) and Corporate Income Tax (CIT)
On November 15, 2021 the President signed into law the Act of 29 October 2021 amending the Personal Income Tax Act, the Corporate Income Tax Act and certain other acts (Polish Journal of Laws 2021, item 2105), which is part of the program known as the “Polish Deal” and introduces... Read More →
Tax residency – Foreign individuals arriving to Poland may become Polish tax residents
Foreign individuals arriving to Poland may become Polish tax residents if their centre of vital (economic or personal) interest moves to Poland, or if they spend in Poland more than 183 days in a tax year. Foreign individuals having their domicile in Poland (i.e. having status of Polish tax residents)... Read More →
