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Found (12) results from author Sören Godniak
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CIT
Retroactive application of Pillar 2 for 2024 – what does it mean and is it worth it?
Background The regulations concerning the top-up taxation of constituent entities of multinational and domestic groups (so‑called Pillar 2) entered into force on 1 January 2025.…
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CIT
Pillar 2 – developments and changes in 2026. Part 1
The new year 2026 has brought a significant number of changes in the area of the top-up tax (the socalled Pillar 2 / GloBE). Although…
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CIT
Can a Ship Create a Permanent Establishment (PE) in Poland?
When analyzing the risk of creating a permanent establishment (PE), which entails the obligation for a foreign taxpayer to pay tax on part of its…
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CIT
Poland simplifies tax-neutral restructurings: Key legislative changes effective mid-September 2025
On 27 August 2025, the President of Poland signed into law a bill aimed at clarifying and facilitating tax-neutral corporate restructurings (here is this blog…
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Tax News
Repeal of Poland’s Tax Strategy Disclosure Requirement - A Welcome Shift Toward Pragmatic Compliance
As of 7 August 2025, Polish taxpayers are no longer required to prepare and publish information regarding the realization of their tax strategy. This change,…
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Tax News
Pillar 2 in Poland – First amendments to the local legislation already planned
Only a few months have passed since the top-up tax (Pillar 2) regulations came into force (in Poland with a one-year delay as of 1…
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Tax News
Pillar 2 - DAC 9 Directive on the top-up tax reporting rules and the related exchange of information adopted by the EU Council
Earlier this week (14 April), the EU Council adopted the DAC9 Directive, which introduces reporting rules for top-up tax purposes and outlines principles of the…
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WHT
Withholding tax (WHT) – problems regarding the application of the look-through approach to foreign dividend payments also in 2025
Withholding tax (WHT) itself and the related concept of the so-called look-through approach (LTA - i.e. the application of WHT preferences to an entity other…
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CIT
Permanent establishment (PE) in Poland because of laptops and remote work?
[Deutsch siehe unten] Taking advantage of the progressing digitalization, many companies decide to employ individuals from various countries as remote workers. If such an employee…
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CIT
WHT: Polish tax authorities confirm the applicability of the 'look through' approach in a non-standard situation
‘Look through’ is a special approach, not directly regulated in Polish tax provisions and its applicability still raises many doubts. Still, practice shows that slowly…
Verbindliche Auskunft zur Anwendung von polnischen Quellensteuerpräferenzen - für wen ist sie (nicht) geeignet?
Das Jahr 2019 ist den meisten als das letzte Jahr vor der noch andauernden Pandemie (Stand: Juli 2022) in Erinnerung geblieben. Ein kleinerer Kreis von…
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CIT
Advance tax ruling for preferential Polish withholding tax treatment – who will (not) benefit?
The year 2019 is remembered by most of us as the last one before the – still ongoing (as of March 2022) – pandemic. However,…
