Tag: Tax
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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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Debt Push-down in Poland: Maximising Benefits
We regularly assist foreign investors entering the Polish market across various sectors. Recently, we introduced institutional and private investors to industries such as food, automotive, technology, and real estate. A common question they ask is whether the debt push-down mechanism can still be used, despite being effectively blocked in Poland in 2018. While interest deductions …
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Landmark Ruling on Board Members’ Liability for Tax Debts
On 22 April 2025, an important judgement of the Court of Justice of the European Union (CJEU) dated 27 February 2025 was published in case C-277/24 (Adjak), marking a significant shift in the approach to board members’ liability for a company’s tax debts. The preliminary ruling was requested by the Provincial Administrative Court in Wrocław …
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