How transfer pricing became key to business survival – a new era of TP control

EUDR

EUDR. Who Is Exempt from the DDS Requirement and Who Must Still Submit It?

The scope of EUDR obligations depends on an entity’s position in the supply chain. Downstream operators, traders and micro and small operators have been exempted from submitting a full DDS, but they remain subject to other requirements under the regulation. Full due diligence obligations continue to apply to operators placing a product on the EU market for the first time or exporting it from the EU. Correct classification of the entity is therefore the foundation of effective EUDR preparation.

EUDR

EUDR and Supply Chain Control. Does the Company Know the Exact Origin of Its Commodities?

EUDR requires companies to identify the origin of commodities down to the specific plot of land. Missing data may prevent the submission of a due diligence statement, restrict the import of certain goods and reveal a lack of effective supply chain control. Key actions include renegotiating supplier agreements, strategically reviewing commodity categories and integrating DDS with ESG reporting.

EUDR

EUDR and Plantation Geolocation. Missing GPS Coordinates May Block Imports into the EU

From 30 December 2026, large and medium sized entities placing products covered by EUDR on the EU market will be required to submit due diligence statements. These statements require geolocation data for every plot of land from which the relevant commodity originates. Missing GPS coordinates may prevent goods from being legally placed on the EU market, which makes appropriate contractual clauses, supplier communication and alternative supply sources particularly important.

GloBE

GloBE and Top Up Tax in Poland. Practical Challenges for Groups in 2026

The Polish legislation implementing the GloBE rules generally applies to fiscal years beginning after 31 December 2024. The regulations cover domestic and multinational groups meeting the EUR 750 million threshold and are intended to ensure a minimum effective tax rate of 15%. In practice, particular attention should be paid to the ETR calculation, transfer pricing, withholding tax and preparations for the new reporting obligations.

SENT

Clothing and Footwear in SENT – New Thresholds and Exemptions from 20 June 2026

Since 17 March 2026, shipments of clothing and footwear have been covered by the SENT monitoring system. From 20 June 2026, the reporting threshold for clothing increased to 31.5 kg of the shipment’s gross weight, while the threshold for footwear remained at more than 20 items. Additional exemptions were also introduced for, among others, domestic business-to-business sales, intra-Community supplies, exports and humanitarian aid.

Transfer pricing adjustments and Pillar 2 – when a TP adjustment requires a GloBE recalculation

A transfer pricing adjustment may affect not only the amount of corporate income tax due, but also the GloBE calculation. Where the value of a transaction determined under the arm’s length principle differs from the value recognised in the entity’s financial accounting net income, an adjustment to GloBE income, covered taxes and the jurisdictional ETR may be required. Adjustments relating to prior years may also trigger a recalculation of the top-up tax.

GloBE

Personal vs. capital links under GloBE – KIS opinion clarifies doubts for family groups

The Director of KIS confirmed that entities linked solely through the same individuals – even related ones holding managerial roles – do not form a GloBE group, because individuals are not entities under the Act. The opinion also reiterates that the EUR 750 million threshold is set on the basis of revenue from the consolidated financial statements, not the taxpayer's own calculations.

CIT

Compensation for Indirect CO2 Emission Costs Exempt from CIT — Supreme Administrative Court Cements a Favourable Line of Case Law

In its judgment of 26 June 2026 (II FSK 1245/25), the NSA confirmed that compensation for indirect CO2 emission costs is exempt from CIT under Article 17(1)(47). This is another taxpayer-friendly ruling consolidating this line of case law.

MDR

Abolition of the "Auxiliary Party" Category in MDR — Two Parties Instead of Three from 1 October 2026

The amendment to the Tax Ordinance of 29 May 2026 abolishes the auxiliary party category in the MDR system from 1 October 2026, leaving the promoter and the beneficiary. Former auxiliary parties, including banks, must verify whether they meet the new definition of a promoter to avoid fiscal-penal liability.

IFT-2R vs TPR-C: When Discrepancies Become a Tax Audit Risk Signal

Discrepancies between IFT-2R and TPR-C are becoming a key audit risk signal. Find out what consequences they can trigger and how to protect against them.

MDR

MDR Reporting from 1 October 2026: Obligation Limited to Cross-Border Arrangements

From 1 October 2026, the MDR obligation will apply only to cross-border arrangements. Find out what this means for your organization and what to do before the deadline.

RET

2025 – Major Changes to Real Estate Tax

Amended property tax regulations will come into force on January 1, 2025.

EUDR

What is EUDR?

The EUDR (Regulation 2023/1115) establishes rules governing the placing on the market and making available on the EU market, as well as the export from the EU, of certain goods.

How Transfer Pricing Has Become Key to Business Survival – A New Era of TP Audits

Today, we can safely say that transfer pricing in Poland has evolved from a formal documentation requirement into a key area of tax risk management.

Legal updates

EUDR. Who Is Exempt from the DDS Requirement and Who Must Still Submit It?

EUDR and Supply Chain Control. Does the Company Know the Exact Origin of Its Commodities?

EUDR and Plantation Geolocation. Missing GPS Coordinates May Block Imports into the EU

GloBE and Top Up Tax in Poland. Practical Challenges for Groups in 2026

Clothing and Footwear in SENT – New Thresholds and Exemptions from 20 June 2026

Transfer pricing adjustments and Pillar 2 – when a TP adjustment requires a GloBE recalculation

Personal vs. capital links under GloBE – KIS opinion clarifies doubts for family groups

Compensation for Indirect CO2 Emission Costs Exempt from CIT — Supreme Administrative Court Cements a Favourable Line of Case Law

Abolition of the "Auxiliary Party" Category in MDR — Two Parties Instead of Three from 1 October 2026

IFT-2R vs TPR-C: When Discrepancies Become a Tax Audit Risk Signal

MDR Reporting from 1 October 2026: Obligation Limited to Cross-Border Arrangements

2025 – Major Changes to Real Estate Tax

What is EUDR?

How Transfer Pricing Has Become Key to Business Survival – A New Era of TP Audits