Publication date: May 23, 2025
The purpose of Regulation (EU) 2022/2560 of the European Parliament and of the Council (FSR) on foreign subsidies distorting the internal market is to enable the European Commission to conduct analyses of subsidies granted by non-EU countries to companies operating in the EU and to combat their negative impact on the single internal market in the European Union.
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Publication date: April 29, 2025
Surreptitious advertising is a form of hidden promotion in which the advertising message is incorporated into editorial content, programs or social media posts without any clear indication that they are commercial in nature. When a famous person publishes a photo promoting a product or service for which they receive remuneration, but does not inform about the commercial nature of this content, it is covert advertising. Such practice can mislead the consumer, as they are not aware that the creator’s opinion is not entirely objective and they may be biased due to the fact that they received remuneration for the product review.
In the context of influencer marketing, this refers to a situation in which an influencer promotes products or services without clearly indicating that it is an advertisement, which may mislead recipients as to the nature of the content.
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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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