Publication date: April 15, 2025

Exit fee is a fee for transferring assets, functions or risks between related entities. It can be understood as remuneration for the transfer of important functions, assets or risks. It is paid during business restructuring, either once or periodicall

On 30 January 2025 there has been issued important interpretation of the Director of the Polish National Revenue Information in respect of exit fee and tax consequences.

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Publication date: April 07, 2025

Payment for advertising and promotional services to a non-resident involves many tax issues that result from domestic regulations as well as international double taxation treaties (DTTs). To properly account for these payments, entrepreneurs must understand both the general rules on withholding tax and the provisions of international treaties that may affect the amount and principles of taxation.

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Publication date: March 31, 2025

Is CIT optimization by two companies in Dutch jurisdiction legal?

Legality in the light of Polish and international law

Market Principle and Transfer Pricing

According to Polish transfer pricing regulations (Articles 11a–11t of the CIT Act) and OECD guidelines, transactions between related entities must be agreed on arm’s length terms principle. If the tax authorities consider that transactions between a Polish and a Dutch company are not arm’s length, they may:

• Estimate the income of the Polish company and impose outstanding CIT.
• Impose a penalty tax rate (50% CIT – Article 19, Section 4 of the CIT Act).
• Apply criminal and fiscal sanctions against the company’s management.

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Publication date: February 19, 2025

Employers often address the question whether it is legal and possible to end employment relationship with the employee and enter into civil law relationship or B2B contract.

This article presents possibilities, risks and limitations of replacing employment contract with civil law contract.

At the outset, it is worth paying attention to the legal provision of the Polish Labour Code, namely Article 22 § 1, which states that:

“§ 1. By entering into an employment relationship, the employee undertakes to perform work of a specified type for the employer and under his supervision and at the place and time designated by the employer, and the employer undertakes to employ the employee for remuneration.”

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Publication date: February 17, 2025

EORI – basic information

EORI, or Economic Operators Registration and Identification, is a system for identifying economic operators used in the European Union to streamline and standardize customs procedures and ensure effective control of operations related to international trade. The introduction of the EORI number results from EU regulations governing the functioning of trade in goods with third countries and is a key element of EU customs policy.

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