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Refusal to Issue an Individual Tax Ruling in Poland: Five Judgments on What the Authority Cannot Refuse
2026-09-30

Category: Taxes and Tax Disputes

Refusal to Issue an Individual Tax Ruling in Poland: Five Judgments on What the...

The phrase “this matter falls outside the competence of the authority issuing the ruling” recurs in…

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The Burden of Proof in GAAR Proceedings
2026-03-25

Category: Taxes and Tax Disputes

The Burden of Proof in GAAR Proceedings

Who Must Demonstrate the Purpose of a Transaction? An Analysis of Eight Judgments of the Supreme…

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Assessing the Applicability of the General Anti-Avoidance Rule Under Polish Tax Law
2026-03-24

Category: Taxes and Tax Disputes

Assessing the Applicability of the General Anti-Avoidance Rule Under Polish Tax Law

An Eight-Test Framework Grounded in Administrative Court Jurisprudence The General Anti-Avoidance Rule (Klauzula przeciwko unikaniu opodatkowania,…

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The Anti-Abuse Clause and the Parent-Subsidiary Dividend Exemption
2026-03-20

Category: Taxes and Tax Disputes

The Anti-Abuse Clause and the Parent-Subsidiary Dividend Exemption

May the tax authority deny the dividend withholding tax exemption to a company that formally satisfies…

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How Forensic Accounting Dismantled a Phantom Empire
2025-12-18

Category: Taxes and Tax Disputes

How Forensic Accounting Dismantled a Phantom Empire

How Dozy Mmobuosi built a fake billion-dollar agritech company out of nothing at all—and what it…

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Reporting of tax schemes MDR Mandatory Disclosure Rules
2025-12-05

Category: Taxes and Tax Disputes

Reporting of tax schemes MDR Mandatory Disclosure Rules

  MANDATORY DISCLOSURE RULES (MDR; reportable tax arrangements; French: déclaration obligatoire des dispositifs transfrontières) constitute a…

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