General tax issues
The system of public levies, choice of taxation form, record-keeping and filing obligations, legislative changes and their practical effects.
Go to area →Knowledge base
Publications
Articles, analyses and case studies based on current legislation, the practice of the tax authorities and the case law of the administrative courts. Publications are written in Polish; selected materials are also available in English, German, Chinese and Korean translation.
Subject areas
Choose an area.
Each publication is assigned to one of the areas. New materials are added as they are prepared.
PIT and CIT
Income, costs, reliefs, Estonian CIT, minimum CIT, financing and filing obligations of individuals and companies.
Go to area →VAT
Invoicing, SAF-T (JPK), the national e-invoicing system (KSeF), intra-Community transactions, import of services, chain transactions and cross-border settlements.
Go to area →Restructuring
Mergers, divisions, conversions, contributions in kind and assessing the tax neutrality of reorganisations.
Go to area →Cross-border settlements
Tax residence, permanent establishment, double tax treaties, withholding tax, working and doing business abroad.
Go to area →Transfer pricing
Documentation thresholds, TPR reporting, safe harbours, intra-group loans and benchmarking analyses.
Go to area →Audits and disputes
Tax audits and proceedings, appeals, complaints to the administrative courts and the rights of the taxpayer.
Go to area →Area
General tax issues
The system of public levies, choice of taxation form, record-keeping and filing obligations, legislative changes and their practical effects.
The legal form of a business in 2026 – what to actually compare before choosing
Sole trader on the tax scale or flat tax, sp. z o.o. under CIT or Estonian CIT: total burden at a PLN 400,000 result and non-tax criteria for the choice.
ZUS and health contributions of entrepreneurs and shareholders – who pays and on what base
Who pays ZUS and health contributions in 2026: sole traders, shareholders, management and supervisory boards. Amounts, bases, employment and PIT deductions.
How much do you really pay as an entrepreneur? A map of taxes and contributions in Poland (2026)
What taxes and contributions does an entrepreneur pay in Poland in 2026? A comprehensive overview: CIT, PIT, VAT, social security (ZUS) and health insurance — rates, thresholds and provisions.
Area
PIT and CIT
Income, costs, reliefs, Estonian CIT, minimum CIT, financing and filing obligations of individuals and companies.
Tax scale, flat tax or lump sum – choosing a form of taxation with the health contribution
Tax scale, flat tax or lump sum in 2026: tax and health contribution for IT services, deductions, work for a former employer and deadlines to change the form.
Poland's Estonian CIT: eligibility, hidden profits and dividend cash costs
Entry, exit, employment, owner payments and cash needed for a dividend. Current Polish rules and the latest bill for 2027.
Tax capital group or holding company – two ways of settling tax for a group of companies
A tax capital group combines income and losses; a holding company exempts dividends and share sale gains. 2026 conditions and why they are mutually exclusive.
Family foundation – the CIT exemption does not cover all revenue or all payments
Family foundation CIT exemption ends at the Article 5 catalogue: 25% outside, 19% on related-party letting, 15% on benefits. Beneficiary PIT and contributions.
R&D relief, IP Box and robotisation – how to combine them and what to do before 2026 ends
Robotisation: 50% of write-offs to the end of the year beginning in 2026. R&D relief (200% of pay) with IP Box, innovative employees and other CIT reliefs.
JPK_CIT and JPK_VAT markings – electronic books of account a year-end export will not fix
JPK_CIT from 1 July 2026: seven months to submit, account tags in the books. JPK_V7: KSeF number, OFF, BFK and DI – when to use which and when to correct.
Selling shares after a restructuring — where the tax cost comes from
The cost on a sale of shares depends on how they were taken up. A contribution in kind, an exchange of shares, a merger and a division carry the historical cost over — they do not restate it.
Area
VAT
Invoicing, SAF-T (JPK), the national e-invoicing system (KSeF), intra-Community transactions, import of services, chain transactions and cross-border settlements.
KSeF in 2026 – the obligation, offline mode and what changes on 1 January 2027
KSeF in 2026: exceptions until the year end, offline and emergency modes, deducting VAT on an invoice from outside the system and changes from 1 January 2027.
White list, split payment and due diligence – payments that protect costs and VAT
Account not on the white list, bypassed split payment: PLN 15,000 threshold, ZAW-NR in 7 days, CIT and PIT costs, joint and several liability, 30% VAT sanction.
Contribution in kind of an enterprise or a ZCP and VAT — why Article 6(1) is not an exemption
Article 6(1) of the VAT Act is an exclusion, not an exemption and not an option for the parties. Check the consequences for the invoice, the deduction, the adjustment under Article 91(9) and PCC.
Area
Restructuring
Mergers, divisions, conversions, contributions in kind and assessing the tax neutrality of reorganisations.
Tax neutrality in restructurings — what it actually means (and what it does not cover)
Tax neutrality in Polish restructurings: PIT deferral, CIT exclusions, share history and economic reasons. Conditions, exceptions and separate tax duties.
Converting a sole trader into a sp. z o.o. — what actually happens to the tax position
Converting a sole trader into a Polish sp. z o.o.: PIT, CIT, VAT, PCC, succession and Estonian CIT. Conditions, exceptions and settlements to prepare before registration.
Merger by acquisition — when it is neutral for CIT and when revenue arises
Polish mergers by acquisition: separate CIT revenue tests, the exception for qualifying mergers without share allocation, losses, tax values and shareholders.
Partial division or division by separation — one word apart in Polish, different consequences
Partial division versus division by separation: who takes up the shares, the ZCP condition on both sides, Article 93c of the Tax Ordinance, CIT, PIT and VAT. Law as at 2026.
An organised part of an enterprise — a test that cannot be passed on paper
A ZCP is a matter of fact as at the date of the transaction, not a name in a contract. Three forms of separation, the case law of the Court of Justice and the consequences of a mistake in VAT, CIT and PCC.
Exchange of shares — how to build a holding structure without paying tax twice
An exchange of shares allows a holding structure to be built without tax in the hands of the shareholder. The majority threshold and the once-only rule are examined for each shareholder separately.
PCC in restructurings — the tax that is remembered too late
PCC is assessed separately from CIT. Rates of 0.5%, 1% and 2%, the exclusions in Article 2(6), the standstill principle on a contribution in kind and the 14-day deadline for the PCC-3 return.
Tax succession — what passes to the successor on a merger, a division or a conversion
Tax succession on a merger, a division and a conversion: Articles 93, 93a § 4, 93c and 93d of the Tax Ordinance. What passes, and what has to be dealt with separately.
Valid economic reasons — evidence that cannot be gathered after the audit
The economic justification for a restructuring as evidential material: the clauses in CIT and PIT, the GAAR, the judgment in Foggia, documents and time limits.
Area
Cross-border settlements
Tax residence, permanent establishment, double tax treaties, withholding tax, working and doing business abroad.
Cross-border reorganisations — the procedure is now simpler, the taxes are not
Cross-border conversion, merger and division: the court's certificate, the opinion of the Head of the KAS, neutrality in CIT, exit tax and a realistic timetable for the operation.
Area
Transfer pricing
Documentation thresholds, TPR reporting, safe harbours, intra-group loans and benchmarking analyses.
Restructuring within a group and transfer pricing — when a transfer of functions has to be paid for
When a reorganisation within a group is a restructuring for transfer pricing purposes, when an exit fee is due and what time limits follow from Articles 11k and 11t of the CIT Act.
Area
Audits and disputes
Tax audits and proceedings, appeals, complaints to the administrative courts and the rights of the taxpayer.
MDR after 1 October 2026 — what still needs reporting
Cross-border scope, hallmarks, promoter and beneficiary duties, annual MDR-3 per arrangement, professional secrecy and individual assessment of historical matters.
Board members' tax liability: Article 116 and CJEU judgments
Liability conditions, bankruptcy, deadlines and defence after the July 2026 CJEU judgment. A practical VAT example and separate fiscal penal rules.
MDR in reorganisations after the reform — five scenarios, EBIT and deadlines
Five reorganisation scenarios, a three-year EBIT calculation, worked MDR deadlines and transitional rules. Reporting is separate from tax neutrality and liability.
Editorial standard
What every piece contains
A simple message should be the result of analysis, not a substitute for it.
01
Thesis
A clearly defined tax problem and scope of analysis.
02
Basis
Specific provisions and the date of the legal status.
03
Practice
Rulings and case law relevant to the problem.
04
Conclusion
Practical effect, risks and courses of action.