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Contractual penalties may constitute tax-deductible costs; tax authorities may not extend the scope of exemptions under Article 16 of the CIT Act.

Expenditure on contractual penalties may constitute tax-deductible costs; tax authorities may not extend the scope of exemptions under Article 16 of the CIT Act In its judgment of 3 July 2025, the Supreme Administrative Court (NSA) referred to the rules for classifying contractual penalties as tax-deductible expenses. The Court’s assessment concerned the interpretation of Article […]

TAX ALERT 2025 / 07 / 18

Ministry of Finance explanations on the form and methods of submitting PIT-11 forms – key information

Although there is still plenty of time left to fulfil the obligation to prepare and submit PIT-11 forms, on 27 June 2025, the Ministry of Finance issued tax explanations regarding the forms and methods of submitting PIT-11 by payers and other entities obliged to prepare them – hereinafter referred to as ‘Explanations’. The Explanations indicate […]

TAX ALERT 2025 / 07 / 16

TP adjustment and VAT – the approach to VAT likely to change

On April 3, 2025, the Advocate General of the Court of Justice of the European Union (“CJEU“) issued an opinion in case C-726/23 (SC Arcomet Towercranes SRL) concerning the VAT on transfer pricing adjustments in intra-group transactions. In the opinion, the Advocate General stated that “remuneration for intra-group services supplied by a parent company to […]

TAX ALERT 2025 / 06 / 02

Inaccuracies in the preparation of financial statements and the risk of forfeiting the right to taxation with Estonian CIT

Recently, the Head of the National Tax Chamber issued several tax interpretations that may affect taxpayers who have opted, or plan to opt, for lump-sum taxation of income during the year (also known as Estonian CIT), by filing a ZAW-RD notice before the end of the tax year adopted by the company. In addition to […]

TAX ALERT 2025 / 05 / 16

Change in jurisdiction of tax offices – revenue limit for the largest taxpayers will increase from €50 million to €100 million

A draft amendment to the Ordinance of the Minister of Finance, Funds and Regional Policy of 28 December 2020, concerning certain taxpayers and remitters for whom tasks are performed by a tax office other than the one with local jurisdiction, has recently been submitted for consultation (the Ordinance)[1]. The Ordinance stipulates, inter alia, which taxpayers fall […]

TAX ALERT 2025 / 05 / 14

New KSeF legislation already published

Dear Sir or Madam, On Friday 11 April 2025, new legislation on the National e-Invoicing System (KSeF), the so-called KSeF 2.0, was published. These are long-awaited provisions that define the main principles of the system and confirm the solutions reached during the public consultations. Major changes – what needs to be known As previously announced, […]

TAX ALERT 2025 / 04 / 14

National E-Invoice System (KSeF) – bill not due until Q2 2025

Dear Sir or Madam, In response to Parliamentary intervention no 8479, the Ministry of Finance has informed that the bill to amend the National E-Invoicing System (KSeF) Law, taking into account the requests submitted during the public consultation (regarding the bill of November 5, 2024), will not be sent to the Council of Ministers for […]

TAX ALERT 2025 / 04 / 09

VAT on TP adjustments – Advocate General gives opinion in the case of SC Arcomet Towercranes SRL (C-726/23)

On April 3, 2025, the Advocate General of the Court of Justice of the European Union (“CJEU“) issued an opinion in case C-726/23 (SC Arcomet Towercranes SRL) concerning the VAT on transfer pricing adjustments in intra-group transactions. Background to the case The case concerns arrangements between Arcomet Romania and its Belgian parent company, whereby the […]

TAX ALERT 2025 / 04 / 04

Revolutionary changes to the Tax Code

On 28 March 2025, a draft amendment to the Tax Ordinance and other tax legislation was published. The proposed changes are systemic in nature – they include provisions on the statute of limitations, remissions and enforcement, as well as fundamental changes to MDR reporting and the activities of tax authorities. The list of proposed changes […]

TAX ALERT 2025 / 04 / 01

Consultations on the alignment of the R&D relief to the GloBE system

The Ministry of Finance has launched a consultation on the proposal to align the R&D relief with the GloBE system. The meeting is scheduled for 21 February 2025 at 13:30 in the building of the Ministry of Finance at 12 Świętokrzyska Street in Warsaw. No hybrid formula is planned for the meeting. Why participate? The […]

TAX ALERT 2025 / 02 / 14

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