Can transfer pricing adjustments expose management to penal fiscal liability? The key issue is not valuation differences, but proving intent. In practice, tax authorities face significant evidentiary challenges, particularly in complex economic analyses where pricing relies on benchmarking and estimation methods.
In February 2026, an administrative court examined whether tax authorities can initiate fiscal penal proceedings solely to suspend the statute of limitations for tax liabilities. The ruling confirmed that when such proceedings are initiated for purely instrumental purposes, they do not produce legal effects and cannot suspend the tax limitation period.
An analysis of whether a tax case may exist before it is formally initiated, including an overview of the different types of tax powers of attorney.
An in-depth look at IP Box relief and how employee remuneration costs qualify, including guidance on allocating overall working time in line with tax interpretations.
An overview of the government’s draft legislation introducing the cash PIT method and proposed changes to personal income tax rules.
A clear explanation of when a management board member may be held liable as a third party, with a focus on strict formal requirements and legal practice.
A clear guide to appealing a ZUS decision in Poland, covering deadlines, formal requirements, and the appeal procedure under social security law.
In recent times, the commencement of each new year has often heralded a barrage of tax law modifications, with new regulations swiftly introduced and taking effect in a short span after their announcement. The initial weeks of the year were typically dedicated to scrutinizing extensive guides and summaries of these changes, with businesses and tax...
In the case of our client, the administrative court confirmed that the restoration of deadlines in tax law is not only permissible but even obligatory. It appears to be one of the most important judgments issued by Polish administrative courts in recent times. According to the court in tax proceedings regarding the correctness of a...
Is it possible to effectively submit a power of attorney for the files of a given tax case before it has been officially initiated? Is a power of attorney submitted for the files of a tax case that (as it later turns out) was not properly initiated (in fact, was not initiated at all) considered valid, and does it constitute authorization to represent the principal in subsequent properly initiated tax proceedings?
