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Tax Overpayment Recovery in Poland. A Practitioner’s Guide for Foreign Clients
2026-05-18

Category: Taxes and Tax Disputes

Tax Overpayment Recovery in Poland. A Practitioner’s Guide for Foreign Clients

The recovery of overpaid Polish tax is, on its surface, a simple proposition: the State has…

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The Inspection That Wouldn’t End
2026-04-06

Category: Taxes and Tax Disputes

The Inspection That Wouldn’t End

How Poland’s Tax Authorities Stretch the Clock—and What Entrepreneurs Can Do About It There is a…

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Empty Invoices Under Polish Law
2026-04-06

Category: Taxes and Tax Disputes

Empty Invoices Under Polish Law

Definition, Consequences, and Defense Strategies for Businesses Operating in Poland [2026] A single invoice whose content…

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Exit Tax and Cryptocurrency
2026-03-28

Category: Tax Residency and International Structures

Exit Tax and Cryptocurrency

Why Poland’s Unrealized Gains Tax Does Not Reach Virtual Currencies — and What This Means for…

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Active Remorse / Voluntary Disclosure Under the Polish Fiscal Penal Code
2026-03-28

Category: White-Collar and Tax Crime

Active Remorse / Voluntary Disclosure Under the Polish Fiscal Penal Code

Statutory Framework, Doctrinal Controversies, and Strategic Implications of Article 16 KKS A taxpayer who has committed…

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Taxation of Gambling Proceeds
2026-03-25

Category: Pending Classification

Taxation of Gambling Proceeds

  The global gambling industry generates revenues in excess of five hundred billion dollars per annum.…

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Tax Residency in International Law: Doctrine, Mechanisms, and Contemporary Challenges
2026-03-23

Category: Tax Residency and International Structures

Tax Residency in International Law: Doctrine, Mechanisms, and Contemporary Challenges

Tax residency (Ger. steuerliche Ansässigkeit; Fr. résidence fiscale) denotes the legal status of a natural or…

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Withholding Tax in the International Tax Order
2026-03-22

Category: Taxes and Tax Disputes

Withholding Tax in the International Tax Order

Introduction: The Enduring Significance of Source-State Taxation Withholding tax—the mechanism by which a source state levies…

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Share Capital Increase
2026-03-22

Category: Companies, Contracts and Governance

Share Capital Increase

Introduction: The Capital Increase as a Taxable Event A share capital increase—the corporate operation by which…

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The Holding Company in International Tax Law
2026-03-22

Category: Tax Residency and International Structures

The Holding Company in International Tax Law

Introduction The holding company—broadly defined as an entity whose principal purpose consists in the acquisition, retention,…

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The Loan Agreement Under Polish Law
2026-03-20

Category: Taxes and Tax Disputes

The Loan Agreement Under Polish Law

The taxation of lending transactions (Pol. opodatkowanie pożyczek; Ger. Darlehensbesteuerung; Fr. taxation des prêts) encompasses the body of rules governing the…

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The Taxation of Gratuitous Transfers: Inheritance and Gift Tax in Poland
2026-02-26

Category: Taxes and Tax Disputes

The Taxation of Gratuitous Transfers: Inheritance and Gift Tax in Poland

INTRODUCTION The taxation of gratuitous transfers—whether effected through testamentary succession, inter vivos gift, or analogous mechanisms…

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Personal Income Tax PIT
2026-02-17

Category: Taxes and Tax Disputes

Personal Income Tax PIT

Personal income tax (Polish: podatek dochodowy od osób fizycznych, PIT; German: Einkommensteuer; French: impôt sur le…

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Civil Transaction Tax in Poland
2026-02-17

Category: Taxes and Tax Disputes

Civil Transaction Tax in Poland

Civil transaction tax (Polish: podatek od czynności cywilnoprawnych; German: Rechtsverkehrsteuer, Grunderwerbsteuer; French: droits d’enregistrement; also rendered…

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Undisclosed Sources of Income
2026-02-15

Category: Taxes and Tax Disputes

Undisclosed Sources of Income

The doctrine of undisclosed sources of income represents one of the most far-reaching powers available to…

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The Principle of In Dubio Pro Tributario
2026-02-15

Category: Taxes and Tax Disputes

The Principle of In Dubio Pro Tributario

In dubio pro tributario (Lat. “when in doubt, in favor of the taxpayer”; Ger. Zweifel zugunsten…

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Statute of Limitations for Tax Obligations
2026-02-12

Category: Taxes and Tax Disputes

Statute of Limitations for Tax Obligations

Statute of Limitations for Tax Obligations (Ger. Verjährung von Steuerschulden; Fr. prescription fiscale) – The statute of…

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Value Added Tax in Poland
2026-02-09

Category: Taxes and Tax Disputes

Value Added Tax in Poland

I. Introduction The Value Added Tax (VAT) stands as the preeminent instrument of indirect taxation across…

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Property Taxation
2026-02-01

Category: Taxes and Tax Disputes

Property Taxation

Theoretical Foundations, Comparative Systems, and Contemporary Challenges I. Introduction The property tax—denominated Grundsteuer in German fiscal…

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Cryptocurrency Taxation
2026-02-01

Category: Crypto and Digital Assets

Cryptocurrency Taxation

Theoretical Foundations, Comparative Frameworks, and the Regulatory Challenges of Decentralized Finance Cryptocurrency taxation encompasses the corpus…

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Cryptocurrency Transaction Reporting
2026-02-01

Category: Crypto and Digital Assets

Cryptocurrency Transaction Reporting

Regulatory Frameworks, Compliance Architectures, and the Challenge of Decentralized Finance The proliferation of blockchain technology and…

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Cryptocurrencies
2026-02-01

Category: Crypto and Digital Assets

Cryptocurrencies

I. Introduction Cryptocurrencies constitute a novel class of digital assets employing asymmetric cryptography to secure transactions…

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The Participation Exemption: Doctrinal Foundations and Contemporary Applications in International Tax Law
2026-01-31

Category: Taxes and Tax Disputes

The Participation Exemption: Doctrinal Foundations and Contemporary Applications in International Tax Law

I. Introduction The participation exemption—known variously as Schachtelprivileg in German jurisprudence, exonération des dividendes in French…

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Related Parties: A Comprehensive Analysis of Affiliated Entities in International Tax Law
2026-01-31

Category: Taxes and Tax Disputes

Related Parties: A Comprehensive Analysis of Affiliated Entities in International Tax Law

Related parties (also termed affiliated entities or associated enterprises) constitute business entities maintaining mutual capital, personal,…

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The Admissibility of Illegally Obtained Evidence
2026-01-25

Category: White-Collar and Tax Crime

The Admissibility of Illegally Obtained Evidence

Consider the following scenario: an entrepreneur suspects that his business partner is embezzling funds from their…

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Foreign Bank Accounts as Instruments of Asset Protection in an Era of Geopolitical Uncertainty
2026-01-20

Category: Tax Residency and International Structures

Foreign Bank Accounts as Instruments of Asset Protection in an Era of Geopolitical Uncertainty

Contemporary wealth preservation increasingly demands jurisdictional diversification as a response to risks that transcend conventional investment…

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Evidence in Tax Proceedings
2026-01-19

Category: Taxes and Tax Disputes

Evidence in Tax Proceedings

Evidence in tax proceedings encompasses the totality of evidentiary instruments employed to establish the factual predicate…

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Annulment of Tax Decisions
2026-01-18

Category: Taxes and Tax Disputes

Annulment of Tax Decisions

Doctrinal Foundations, Comparative Frameworks, and Procedural Mechanisms The annulment of a tax decision (Aufhebung des Steuerbescheids…

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Double Taxation Agreements: Foundations, Architecture, and Contemporary Challenges in International Tax Law
2026-01-11

Category: Taxes and Tax Disputes

Double Taxation Agreements: Foundations, Architecture, and Contemporary Challenges in International Tax Law

Introduction Double taxation agreements—known variously as tax treaties, Doppelbesteuerungsabkommen in German jurisprudence, and conventions fiscales contre…

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Corporate Demergers: Tax Consequences and Regulatory Framework
2026-01-05

Category: Companies, Contracts and Governance

Corporate Demergers: Tax Consequences and Regulatory Framework

The corporate demerger—variously denominated as a scission, division, or spin-off depending upon jurisdiction and transactional form—constitutes…

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