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The Naked Taxpayer. When the Tax Authorities Come to OnlyFans
2026-07-12

Category: Taxes and Tax Disputes

The Naked Taxpayer. When the Tax Authorities Come to OnlyFans

OnlyFans creators around the world are discovering a painful truth: nothing on the internet ever disappears,…

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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 Holding Exemption and Probatio Diabolica
2026-03-22

Category: Tax Residency and International Structures

The Holding Exemption and Probatio Diabolica

The Holding Exemption and Probatio Diabolica When the Tax Authority Ignores the Supreme Court and Demands…

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Withholding Tax Agent Obligations
2026-03-20

Category: Taxes and Tax Disputes

Withholding Tax Agent Obligations

When a Certificate of Residence and a Statutory Declaration Are Not Enough A Polish company distributes…

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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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Beneficial Ownership and Dividend Distributions
2026-01-31

Category: Taxes and Tax Disputes

Beneficial Ownership and Dividend Distributions

In December 2025, the Regional Administrative Court in Olsztyn rendered a judgment that may significantly reshape…

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Taxation of foreign-source income: territorial, worldwide, and citizenship-based system
2025-12-05

Category: Taxes and Tax Disputes

Taxation of foreign-source income: territorial, worldwide, and citizenship-based system

  TAXATION OF FOREIGN-SOURCE INCOME—TERRITORIAL, WORLDWIDE, AND CITIZENSHIP-BASED SYSTEMS constitutes a fundamental taxonomy of approaches employed…

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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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