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Corporate tax
Transfer pricing
VAT
Establishment a permanent establishment and transfer pricing obligations
Establishment a permanent establishment and transfer pricing obligations Conducting business in another...
Are you submitting a TPR? - Don't forget about complimentary services
Are you submitting a TPR? – Don’t forget about complimentary services There are only 3 days...
Last call: Significant changes to take info account before submitting TPR
When planning to submit transfer pricing information (hereinafter: TPR) for the tax year beginning after...
Impact of classification of goods on customs duties - opinion of the Advocate General of the CJEU in case C-104/23
On January 18, 2024, the Advocate General of the Court of Justice of the European Union issued an opinion...
Who submits the TPR form after a merger?
The dynamically changing economic situation, continuous development of competition in most industries...
Planning, rather than mere compliance, is the essence of transfer pricing
For most taxpayers, transfer pricing is associated with numerous and complex formal requirements that...
Use of OECD guidelines in EU jurisprudence
At the end of last year, the outcome of the Amazon group’s tax dispute was widely reported in the...
SUP fee - ecology yes, but with VAT?
This year, when selling food or beverages in single-use packaging to consumers, a SUP fee they must be...
Changes in the base interest rate and margins – announcement regarding transfer pricing!
The new Notice of the Minister of Finance on the announcement of the type of base interest rate and margin...
Are transactions between spouses subject to transfer pricing obligations?
On July 3, 2023, a parliamentary interpellation was submitted to the Minister of Finance regarding the...
TP adjustments - to show or not to show in VAT settlements?
Many companies in capital groups make an annual price adjustment in transactions with a related company...
Can hard-to-value intangibles actually be problematic?
We recently wrote on our blog about intangible assets and accounting for them. In this post, we would...
Factors affecting the tariff classification of goods
The Court of Justice of the European Union (CJEU) confirmed in its judgment of 16 November 2023 (C-366/22...
What not to forget when filling out the TPR for 2022?
Although the deadlines for filing the transfer pricing information (TPR) form for 2022 are to be extended...
Benchmarking analysis or compliance analysis - how to report in the TPR form?
One of the key elements of transfer pricing documentation is a transfer pricing analysis. It can be prepared...
Capital increases and surcharges vs. TP obligations
One of the types of controlled transactions that can be carried out between related parties are capital...
Technical aspects of submitting for the 2022 TPR form. How to do it?
The deadline for submitting the 2022 TPR form (for taxpayers whose tax year coincides with the calendar...
TPR as a tool for typing for tax audit
When trying to complete the TPR form, it is good to remember what the primary purpose of this reporting...
ATAD 2 rules in Poland – latest practice
General rules The regulations on preventing hybrid mismatches in Poland came into force on January 1,...
Minimum income tax returns
On January 1, 2024, the minimum corporate income tax provisions of Article 24ca of the CIT Law will begin...
Local file documentation - the last straight
In 2023, the deadlines for completing transfer pricing obligations for 2022 have been shortened. The...
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VAT classification of sales of commercial real estate as the Organised Part of an Enterprise
Judgment of the Supreme Administrative Court of 28 July 2023 (ref. I FSK 892/18) The recently announced...
Polish provisions restricting the right to be granted interest on overpayments inconsistent with EU law
On 8 June 2023, the Court of Justice of the EU issued a judgment in case C-322/22, in which it stated...
When does a company act as a private investor?
The rule under Polish tax law is a one-off tax levied on the same transaction, whereby – pursuant...
EU customs reform - proposals of the European Commission
On May 17, 2023, the European Commission presented the first package of changes to EU customs law. The...
VAT treatment of NFT tokens in the opinion of the European Commission
On March 21, 2023, the European Commission published a working paper (Working Paper no. 1060 of the EU...
CJEU restricts the possibility of being prosecuted twice for the same offence
In the judgment of 4 May 2023 in Case C-97/21 MV – 98, the CJEU found that provisions of the Member...