Tax News

You will find here changes in the tax regulations discussed and commented by Forvis Mazars' experts.

Transfer Pricing Adjustments after 2025 – new challenges in CIT, VAT and KSeF

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The beginning of 2026 is the time when many multinational groups make transfer pricing adjustments for the 2025 fiscal year. Such settlements are now closely scrutinized by tax authorities, not only from a CIT perspective but also in terms of VAT and KSeF obligations.

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MDR at the 2025 year-end close

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In February the draft amendments to the Polish Tax Ordinance were published for legislative process in the Parliament, providing for simplifications in Mandatory Disclosure Rules (MDR) reporting. Until the new regulations enter into force, however, taxpayers should continue to apply the current MDR framework. In practice, this means that when finalising the financial statements, the CIT-8 computation and the review of transactions for 2025, it is worth carrying out a structured review of events that may meet the hallmarks of MDR reportable arrangements.

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Shifted Income Tax (Shifted Profits Tax)

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Scope and mechanics of the Shifted Income Tax (Shifted Profits Tax), the categories of costs covered by the regulations and the key verification criteria from a Polish CIT taxpayer perspective.

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Qualified Domestic Top-up Tax (QDMTT): implementation obligations in Poland

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Obligations related to the implementation of the Qualified Domestic Top-up Tax (QDMTT) by Poland

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Car leasing and depreciation changes from 2026

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On January 1, 2026, regulations reducing the limit of expenses for the purchase or leasing of a passenger car that can be classified as tax-deductible costs from PLN 150,000 to PLN 100,000 are to come into force.

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Poland: VAT in the Digital Age (ViDA) and E-Invoicing Requirements

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The Minister of Finance and Economy has signed four key regulations governing the operation of the National e-Invoicing System (KSeF). The new provisions clarify the rules for issuing structured invoices, using the system, and reporting data in tax records. These changes will take effect with the launch of KSeF on February 1, 2026.

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B2B Contracts in Light of the Draft Amendment Expanding Powers of the National Labour Inspectorate (PIP)

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At the turn of August and September, a draft act (ID: UD283) was published, proposing an expansion of the powers of the National Labour Inspectorate, which was ultimately approved by the Council of Ministers in its revised form last week. Under the proposed wording, the labour inspector would be able to unilaterally determine the existence of an employment relationship, without referring the matter to court. From the date of the decision, obligations concerning social security contributions and advance PIT payments would arise.

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General Ruling of the Minister of Finance on the Qualification of Share Capital Increase in the Context of MDR Reporting

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On 29 July 2025, the Minister of Finance issued General Ruling No. DTS5.8092.3.2025 concerning the qualification of a limited liability company's share capital increase under the Mandatory Disclosure Rules (MDR). The document clarifies previous practical uncertainties, particularly with regard to capital increases made with so-called ‘agio’ (share premium exceeding the nominal value of shares).

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New obligation of JPK CIT reporting starting from 2025 or 2026

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We would like to inform you about the recently implemented Polish tax legislation in the area of Corporate Income Tax (“CIT”) reporting that will have impact on all CIT taxpayers in Poland, presenting an overview of the new legislation, together with our comments and recommendations.

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CIT Increase for Banks in Parliament

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CIT Increase for Banks in Parliament

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