Tag: Tax
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Spotlight on VAT Treatment of Transfer Pricing Adjustments
The value-added tax (VAT) treatment of transfer pricing adjustments has recently taken centre stage following an opinion from an advocate general at the Court of Justice of the European Union in the Arcomet Towercranes case (C-726/23). The opinion raises significant questions about the proper handling of such adjustments under VAT regulations. With a final ruling …
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Collective Tax Residency Certificates – Practical Step Forward
In a recent article for Prawo.pl (Wolters Kluwer), Piotr Prokocki, Head of Tax at Penteris, comments on an important development in Polish tax practice: the acceptance of collective tax residency certificates by the National Tax Information Office (KIS). This shift promises to ease the compliance burden on Polish companies making cross-border payments to foreign, tax-transparent …
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Equality for Investment Funds – CJEU Judgment
In February 2025, the Court of Justice of the European Union (CJEU) issued a judgment which opened up the possibility of benefiting from corporate income tax (CIT) exemptions for all foreign funds invested in Poland. Controversial Provisions Investment funds are divided into two categories: externally managed funds, and internally managed funds. The former are managed …
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