An American L.L.C. is invisible to the I.R.S., a shadow of its owner to Polish tax…
OnlyFans creators around the world are discovering a painful truth: nothing on the internet ever disappears,…
The recovery of overpaid Polish tax is, on its surface, a simple proposition: the State has…
In March of 2024, a judge in the Rolls Building, on Fetter Lane in London, delivered…
Definitional Boundaries, Regulatory Scrutiny, and Recurring Disputes The Organized Part of an Enterprise and VAT Exclusion…
When a gas-station manager in Poland spent four years selling fictitious invoices under her employer’s name,…
How Poland’s Tax Authorities Stretch the Clock—and What Entrepreneurs Can Do About It There is a…
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 Dong Yang Electronics (C-547/18) and the Limits of a Service Provider’s Duty of…
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…
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,…
Introduction: The Enduring Significance of Source-State Taxation Withholding tax—the mechanism by which a source state levies…
The taxation of lending transactions (Pol. opodatkowanie pożyczek; Ger. Darlehensbesteuerung; Fr. taxation des prêts) encompasses the body of rules governing the…
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…
INTRODUCTION The taxation of gratuitous transfers—whether effected through testamentary succession, inter vivos gift, or analogous mechanisms…
Consensus, Convalidation, and the Limits of Retroactive Unwinding Under Polish Gift Tax Law Monetary gifts between…
Personal income tax (Polish: podatek dochodowy od osób fizycznych, PIT; German: Einkommensteuer; French: impôt sur le…
Civil transaction tax (Polish: podatek od czynności cywilnoprawnych; German: Rechtsverkehrsteuer, Grunderwerbsteuer; French: droits d’enregistrement; also rendered…
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 …
The doctrine of undisclosed sources of income represents one of the most far-reaching powers available to…
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…
