The Look-Through Approach in Polish Case Law I. Introduction: The Beneficial Owner Clause and Preferential WHT…
The curious journey of wiretap evidence from criminal investigations to tax disputes—and the courts that decide…
The tax audit protocol (protokół kontroli podatkowej) occupies a position of singular importance within the Polish…
Prejudgment security over taxpayer assets presents an instrument of dual character: on one hand, it safeguards…
How to Shield Your Business Within the Law Every entrepreneur bears the risk of poor decisions,…
When the Tax Authority Comes Knocking Asset seizure by the tax office represents the ultimate coercive…
Official Documents, Counter-Evidence, and the Limits of Administrative Discretion This Article examines a landmark decision by…
Abstract: This article examines the intersection of taxpayer good faith and the fundamental right to deduct…
The statement of reasons accompanying a tax decision constitutes far more than a mere formality—it represents…
The Jurisprudence of Reasoned Decision-Making A certain tax dispute concerning undisclosed sources of income persisted for…
Causation, Contribution, and the Limits of Fiscal Immunity Abstract: This article examines a consequential ruling by…
When Previously Known Circumstances Cannot Justify Resumption of a Final Determination The reopening of tax proceedings…
The Full 19% Statutory Rate Prevails Over Treaty Limitations Polish taxpayers may reduce their withholding tax…
Introduction An unfavorable judgment from the Voivodeship Administrative Court need not constitute the terminus of administrative…
Exit Taxation: Doctrinal Foundations, Comparative Framework, and Evolving Jurisprudence Exit taxation—variously denominated as the expatriation tax,…
Documenting intra-Community supply of goods for 0% VAT – on 13 November 2025, the Court of…
Reconciling Efficacy with Fundamental Rights Under Abstract: This article examines the instruments of extended confiscation and…
A tax decision (decyzja podatkowa) constitutes an authoritative determination by tax authorities issued in administrative…
In October of 2025, Poland’s Supreme Administrative Court confronted a question as old as art itself:…
Active remorse (czynny żal) constitutes a foundational doctrine in criminal law, fiscal criminal law, and…
Depending on the chosen financing model for the investments, the tax consequences of such transactions…
Bitcoin taxation and change of tax residence – can obtaining second citizenship shield an investor from…
A twenty-one-year-old student in London recently discovered that Instagram posts can lead directly to criminal…
The judgment of the Court of Justice of the European Union rendered on October 23,…
Creators on OnlyFans are discovering a painful truth: nothing on the Internet ever truly disappears, tax…
On September 4, 2025, Advocate General Juliane Kokott issued her opinion in Case C-121/24, which…
The use of offshore structures in international business remains one of the most contentious aspects of…
The Court of Justice of the European Union’s judgment of October 9, 2025, in Case…
The proposed amendment to Poland’s Tax Ordinance Act, which would impose tax secrecy obligations upon…
What Is Poland’s Foreign Income Lump Sum Taxation? In February 2025, the Polish National Tax Information…
