tax consultancy

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

The Principle of In Dubio Pro Tributario

In dubio pro tributario (Lat. “when in doubt, in favor of the taxpayer”; Ger. Zweifel zugunsten…

Category: Taxes and Tax Disputes

Tolling and Interruption of the Statute of Limitations on Tax Obligations: When the Fisc...

When the Fisc Buys Time The statute of limitations on tax obligations constitutes one of the…

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: Taxes and Tax Disputes

The Participation Exemption: Doctrinal Foundations and Contemporary Applications in International Tax Law

I. Introduction The participation exemption—known variously as Schachtelprivileg in German jurisprudence, exonération des dividendes in French…

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

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: Tax Residency and International Structures

When Tax Planning Goes Spectacularly Wrong

The use of offshore structures in international business remains one of the most contentious aspects of…

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

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: 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: Family Wealth and Succession

The Dissolution and Liquidation of Family Foundations in Organization: A Critical Analysis of Statutory...

  The Polish family foundation framework introduces a novel and problematic legal construct: the “family foundation…