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…
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…
Polish Courts and the Expanding Doctrine of Manifest Unconstitutionality How the Kielce Administrative Court’s 2023 Ruling…
Tax audits and regulatory inspections of business operations constitute among the most burdensome forms of state…
Preferential Tax Treatment Under Polish Law and the Approaching 2026 Legislative Reform I. Introduction Equity-based and…
In December 2025, the Regional Administrative Court in Olsztyn rendered a judgment that may significantly reshape…
The curious journey of wiretap evidence from criminal investigations to tax disputes—and the courts that decide…
The utilization of trademark licensing arrangements between affiliated entities represents a prevalent tax planning mechanism across…
Official Documents, Counter-Evidence, and the Limits of Administrative Discretion This Article examines a landmark decision by…
The statement of reasons accompanying a tax decision constitutes far more than a mere formality—it represents…
When Previously Known Circumstances Cannot Justify Resumption of a Final Determination The reopening of tax proceedings…
Introduction The principle of limited liability constitutes one of the foundational pillars upon which the modern…
Documenting intra-Community supply of goods for 0% VAT – on 13 November 2025, the Court of…
When tax authorities arrive to conduct an audit, the entrepreneur confronts a peculiar species of visitor—one…
In October of 2025, Poland’s Supreme Administrative Court confronted a question as old as art itself:…
On the day Roger Ver renounced his United States citizenship in a cramped room at the…
A twenty-one-year-old student in London recently discovered that Instagram posts can lead directly to criminal…
Creators on OnlyFans are discovering a painful truth: nothing on the Internet ever truly disappears, tax…
On September 4, 2025, Advocate General Juliane Kokott issued her opinion in Case C-121/24, which…
The Court of Justice of the European Union’s judgment of October 9, 2025, in Case…
