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.
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.
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.
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)
Neutrality in a reorganisation is conditional and usually means tax deferral. Check the CIT and PIT conditions and what falls outside them.
Converting a sole trader into a sp. z o.o. — what actually happens to the tax position
Converting a sole trader's business into a sp. z o.o. is neutral on the registration date but changes the PIT, CIT and VAT regime. What to settle before the conversion date.
Merger by acquisition — when it is neutral for CIT and when revenue arises
Merger by acquisition and CIT: Article 12(1)(8c), (8d), (8f) and (8ba), the exclusions, losses, reverse mergers, PCC and VAT. Law as at 2026.
Division by spin-off or by separation — one word apart, different consequences
Spin-off versus 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 from 1 October 2026 — the end of domestic reportable arrangements in reorganisations
From 1 October 2026 MDR covers cross-border arrangements only. Outstanding domestic obligations continue, and MDR-3 is due by the end of the fourth month after the tax year.
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.