tax advisory

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,…

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…

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…

Equity-Based Incentive Programs in Multinational Corporate Groups

Preferential Tax Treatment Under Polish Law and the Approaching 2026 Legislative Reform I. Introduction Equity-based and…

Category: Crypto and Digital Assets

Taxation of Genesis Token Allocations

Genesis allocation—the initial distribution of tokens created contemporaneously with the establishment of a new blockchain network—presents…

Category: Pending Classification

How the Tax Office Enforces Tax Liabilities in Poland

When the Tax Authority Comes Knocking Asset seizure by the tax office represents the ultimate coercive…

Category: Taxes and Tax Disputes

Reopening of Tax Proceedings

When Previously Known Circumstances Cannot Justify Resumption of a Final Determination The reopening of tax proceedings…

Category: Taxes and Tax Disputes

Piercing the Corporate Veil for Tax Obligations

The Derivative Liability of Corporate Officers Under Polish Fiscal Law I. Introduction The limited liability corporation…

Category: Taxes and Tax Disputes

Tax Decision

  A tax decision (decyzja podatkowa) constitutes an authoritative determination by tax authorities issued in administrative…

Category: Taxes and Tax Disputes

When #LuxuryLife Becomes Evidence: How Social Media Posts Lead Straight to Tax Court

  A twenty-one-year-old student in London recently discovered that Instagram posts can lead directly to criminal…

Category: Taxes and Tax Disputes

Physical Movement of Goods as a Sine Qua Non Condition for Intra-Community Supply: An...

  The judgment of the Court of Justice of the European Union rendered on October 23,…

Category: Taxes and Tax Disputes

The CJEU Xyrality Judgment: A Landmark Decision for Mobile Application Developers

The Court of Justice of the European Union’s judgment of October 9, 2025, in Case C-101/24…

Category: Tax Residency and International Structures

The Vanuatu Passport Trap: When a Golden Ticket Becomes a Liability

  Citizenship-by-investment programs promise global mobility. They often deliver something closer to house arrest.   Picture…

Category: Taxes and Tax Disputes

Points, Vouchers, or Discounts? The CJEU’s Taxonomical Approach to Loyalty Programs Under VAT Law

  Advocate General Juliane Kokott’s Opinion of September 11, 2025, in Case C-436/24 Skatteverket v. Lyko…

Category: Taxes and Tax Disputes

VAT Principles for Gaming “Gold” in Light of Case C-472/24: A Critical Analysis of...

  Can one conceive of circumstances wherein virtual objects from computer games generate tax liabilities reaching…

Category: Taxes and Tax Disputes

The Stand-Still Principle in Civil Transaction Taxes

The decision rendered by the Regional Administrative Court in Gdańsk on September 2, 2025 (I SA/Gd…

Category: Tax Residency and International Structures

Foreign Controlled Foreign Corporation Units and the Utilization of Prior Year Losses: A Polish...

  The taxation of controlled foreign corporations (CFC) presents a complex paradigm wherein income calculations must…

The Calculation of Tax Liability for Controlled Foreign Corporations: A Dual-Method Framework

  The taxation of controlled foreign corporations represents one of the most sophisticated challenges in contemporary…

Powers of attorney as criteria for de facto control in Polish controlled foreign corporation...

  Controlled foreign corporation (CFC) legislation constitutes one of the most significant anti-avoidance mechanisms in the…

Category: Tax Residency and International Structures

Tax Advantages of U.S. LLCs for International Business: A Comprehensive Analysis

  Understanding the true nature of LLC taxation is crucial for foreign investors. LLCs are not…