What Zondacrypto’s Withdrawal Crisis, a Century of Financial Panics, and the Psychology of Sunk Costs Tell…
In our previous analysis, we traced the anatomy of a liquidity crisis at Zondacrypto — Poland’s…
When a gas-station manager in Poland spent four years selling fictitious invoices under her employer’s name,…
Seven Years, Two Witnesses, and Nothing to Show for It In the autumn of 2021, a…
Definition, Consequences, and Defense Strategies for Businesses Operating in Poland [2026] A single invoice whose content…
Remedies for Taxpayers Confronting National Noncompliance with EU Law The accession of Member States to the…
The CJEU’s Ruling in Titanium Ltd (C-931/19) and Its Implications for Cross-Border Taxation The concept of…
The Punitive Seventy-Five Percent Tax Rate Among the most severe provisions in the Polish tax code,…
When Article 16 of the Fiscal Penal Code Fails to Shield the Offender? Voluntary disclosure (czynny…
Why Poland’s Unrealized Gains Tax Does Not Reach Virtual Currencies — and What This Means for…
Statutory Framework, Doctrinal Controversies, and Strategic Implications of Article 16 KKS A taxpayer who has committed…
Who Must Demonstrate the Purpose of a Transaction? An Analysis of Eight Judgments of the Supreme…
An Eight-Test Framework Grounded in Administrative Court Jurisprudence The General Anti-Avoidance Rule (Klauzula przeciwko unikaniu opodatkowania,…
A Dual-Jurisdiction Analysis Under Polish Domestic Law and the 1974 Poland–United States Tax Convention Robert Nogacki…
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…
Consensus, Convalidation, and the Limits of Retroactive Unwinding Under Polish Gift Tax Law Monetary gifts between…
Trump v. IRS: A $10 Billion Claim for Unauthorized Disclosure of Tax Returns On January 29,…
I. Introduction: The Problem of Dual Tax Regimes The proper tax characterization of a loan agreement…
The Demise of the “Near-Sole Shareholder” Doctrine and the Emerging Problem of Sham Multi-Member Structures …
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…
For nearly five years, the tax authority pursued fruitless enforcement proceedings against a company’s assets —…
Polish Courts and the Expanding Doctrine of Manifest Unconstitutionality How the Kielce Administrative Court’s 2023 Ruling…
When the Fisc Buys Time The statute of limitations on tax obligations constitutes one of the…
Tax audits and regulatory inspections of business operations constitute among the most burdensome forms of state…
