When a gas-station manager in Poland spent four years selling fictitious invoices under her employer’s name,…
When Article 16 of the Fiscal Penal Code Fails to Shield the Offender? Voluntary disclosure (czynny…
Statutory Framework, Doctrinal Controversies, and Strategic Implications of Article 16 KKS A taxpayer who has committed…
An Eight-Test Framework Grounded in Administrative Court Jurisprudence The General Anti-Avoidance Rule (Klauzula przeciwko unikaniu opodatkowania,…
The Holding Exemption and Probatio Diabolica When the Tax Authority Ignores the Supreme Court and Demands…
When a Failed Transaction Does Not Constitute Taxable Income Does a failed conversion of a loan…
When a Certificate of Residence and a Statutory Declaration Are Not Enough A Polish company distributes…
May the tax authority deny the dividend withholding tax exemption to a company that formally satisfies…
In dubio pro tributario (Lat. “when in doubt, in favor of the taxpayer”; Ger. Zweifel zugunsten…
I. Introduction Many entrepreneurs regard the principle of in dubio pro tributario as a trump card…
I. Introduction: The Tension Between Fiscal Efficiency and Financial Privacy Few questions in modern tax law…
Poland built an algorithm to catch tax cheats. It works—except when it doesn’t. On a Monday…
Tax audits and regulatory inspections of business operations constitute among the most burdensome forms of state…
Preferential Tax Treatment Under Polish Law and the Approaching 2026 Legislative Reform I. Introduction Equity-based and…
Genesis allocation—the initial distribution of tokens created contemporaneously with the establishment of a new blockchain network—presents…
In December 2025, the Regional Administrative Court in Olsztyn rendered a judgment that may significantly reshape…
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…
