On 17 January in Lublin, Paczuski Taudul Tax Advisors signed a cooperation agreement with the KUL Law Students’ Scientific Society. Under this cooperation, top law students from the John Paul II Catholic University of Lublin (KUL) will have the opportunity to expand their practical knowledge of taxation through internships and paid traineeships at our firm.

We foster the development of future tax advisors and lawyers: Andrzej Paczuski, partner at Paczuski Taudul, delivered a lecture for participants of “Tax Bridges” (Mosty Podatkowe) - a nationwide initiative of law students from the three largest universities in Poland. The meeting focused on family foundations - their role, structure, and importance in succession planning for family-owned businesses.

No possibility to apply a transfer pricing adjustment under Article 11e of the CIT Act if the financial result falls within the arm’s length range of the benchmarking analysis - individual ruling of the Director of the National Revenue Information (KIS) of 8 November 2024, ref. nos. 0111-KDIB1-1.4010.535.2024.4.BS, 0111-KDIB3-3.4012.413.2024.6.AW

The beginning of the year is the right time to plan activities related to fulfilling ownership structure reporting obligations applicable to real estate companies. For taxpayers whose tax year corresponds to the calendar year, the deadline for 2024 reporting is 31 March 2025. Nonetheless, it is advisable to begin preparations for meeting these obligations already at this stage.

We would like to remind you that, for taxpayers whose tax year coincides with the calendar year, the CIT settlement for 2024, due by 31 March 2025, will be the first requiring an analysis of whether the taxpayer is subject to the minimum CIT. Accordingly, it is advisable to begin, already at this stage, actions aimed at determining whether the company will be obliged to pay this tax.

An end to suspending the limitation period upon initiation of Fiscal Penal Code proceedings? Ministry of Finance announcements

On 21 November 2025, the Sejm passed an amendment to the Act on the system for managing emissions of greenhouse gases and other substances [hereinafter: the Amendment], the purpose of which is to implement the Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon border adjustment mechanism [hereinafter: the CBAM Regulation] into the Polish legal order. At present, the Amendment is awaiting the signature of the President of the Republic of Poland.

On 4 December 2025, a draft amendment to the Act on Value Added Tax was published [ref. no. UD327, hereinafter: the Draft], providing, inter alia, for an increase in the VAT rate on non-alcoholic substitutes for alcoholic beverages and energy drinks.

Paczuski Taudul joined as a strategic partner of the Disputatio Iuridica event entitled “State and law – contemporary issues, challenges and threats”, hosted by the Faculty of Law and Administration at the Maria Curie-Skłodowska University in Lublin. The debate, focusing on the rule of law and judicial independence, brought together leading representatives of legal academia and the judiciary.

On 27 February 2025, the Court of Justice of the European Union (CJEU) delivered a landmark judgment in the Polish case C-277/24 (the “Judgment”), concerning the procedure for determining the joint and several liability of third parties for the tax liabilities of a legal person.

Paczuski Taudul joined as a strategic partner of the Disputatio Iuridica event entitled “State and law – contemporary issues, challenges and threats”, hosted by the Faculty of Law and Administration at the Maria Curie-Skłodowska University in Lublin. The debate, focusing on the rule of law and judicial independence, brought together leading representatives of legal academia and the judiciary.

The National e-Invoicing System (KSeF) is a challenge that requires expertise and experience both in taxation and information technology. To provide our clients with comprehensive support, Paczuski Taudul has established cooperation with Pentacomp - an expert in modern IT solutions.

On 2 October, an inaugural lecture was held at the Faculty of Law and Administration at the Maria Curie-Skłodowska University (UMCS) in Lublin to mark the launch of a new degree programme titled “Tax Advisory and Tax Administration”. Paczuski Taudul is a strategic partner of this programme.

250 students of the Faculty of Law and Administration at the University of Warsaw took part in the “freshers’ camp” in Lidzbark - an event supported by Paczuski Taudul.

We foster the development of future tax advisors and lawyers: Andrzej Paczuski, partner at Paczuski Taudul, delivered a lecture for participants of “Tax Bridges” (Mosty Podatkowe) - a nationwide initiative of law students from the three largest universities in Poland. The meeting focused on family foundations - their role, structure, and importance in succession planning for family-owned businesses.

On 17 January in Lublin, Paczuski Taudul Tax Advisors signed a cooperation agreement with the KUL Law Students’ Scientific Society. Under this cooperation, top law students from the John Paul II Catholic University of Lublin (KUL) will have the opportunity to expand their practical knowledge of taxation through internships and paid traineeships at our firm.

On 4 December 2025, a draft amendment to the Act on Value Added Tax was published [ref. no. UD327, hereinafter: the Draft], providing, inter alia, for an increase in the VAT rate on non-alcoholic substitutes for alcoholic beverages and energy drinks.

On 21 November 2025, the Sejm passed an amendment to the Act on the system for managing emissions of greenhouse gases and other substances [hereinafter: the Amendment], the purpose of which is to implement the Regulation (EU) 2023/956 of the European Parliament and of the Council of 10 May 2023 establishing a carbon border adjustment mechanism [hereinafter: the CBAM Regulation] into the Polish legal order. At present, the Amendment is awaiting the signature of the President of the Republic of Poland.

On 23 September 2025, the assumptions for a draft amendment to the VAT Act and the Act on the Principles of Taxpayer and Payer Registration and Identification were published (No. UD314, hereinafter: the Amendment). The Ministry of Finance has announced that the draft is expected to be adopted by the Council of Ministers in Q4 2025.

On 22 September 2025, the Supreme Administrative Court (NSA), sitting in an extended panel of seven judges, passed a judgment favourable for the taxpayer (case file No. I FSK 1519/21), in which it ruled that, for the purposes of calculating the excise duty exemption for electricity generated from renewable energy sources (RES), the decisive rate is the excise duty rate applicable at the time energy was produced, and not the rate valid at the time of the redemption of guarantees of origin issued for that energy (so-called “green certificates”).
Accordingly, the extended panel of the NSA confirmed the position previously expressed by the Court in several earlier judgments delivered by ordinary panels.

In August 2025, assumptions were published for a draft act extending the powers of the State Labour Inspectorate (PIP) with respect to challenging forms of engagement other than employment contracts.

In mid-August 2025, the Team for Combating Aggressive Tax Planning and the KAS Competence Centre (based at the Lesser Poland Customs and Tax Office in Kraków) commenced operations – new bodies established by the Minister of Finance and Economy in close cooperation with the Head of the National Revenue Administration (KAS).

Their activities are will focus on combating aggressive tax optimisation in corporate income tax (CIT), particularly with regard to cross-border settlements. The Ministry explains that this initiative responds to the high effectiveness of transfer pricing audits in recent years, emphasising that transfer pricing remains the most commonly used tool by taxpayers to reduce their taxable income.

The Minister of Finance, Andrzej Domański, together with the Undersecretary of State at the Ministry of Finance, Jarosław Neneman, presented (once again) the assumptions of a draft legislative amendment on family foundations at a press conference. Accordingly, the Ministry of Finance intends to tighten the regulations governing the taxation of family foundations to counteract practices of aggressive tax optimisation.

On 24 June 2025, the Sejm adopted the Act amending the Value Added Tax Act (Sejm print No. 1232) [hereinafter: the Amendment], aimed at increasing the revenue threshold that entitles taxpayers to apply the so-called small business VAT exemption under Article 113 of the VAT Act. Pursuant to the Amendment, as of 1 January 2026, the VAT exemption will be available to taxpayers whose annual sales (including VAT) do not exceed PLN 240,000. The current threshold is PLN 200,000 per year.

On 1 July 2025, the Regulation of the Minister of Finance of 27 May 2025 (Journal of Laws, item 698; hereinafter, “the Amending Regulation”) will come into effect. The Amending Regulation updates the Regulation on templates for excise duty and excise duty prepayment returns (Journal of Laws 2024, item 1082, as amended) and introduces new excise duty return forms as follows:

• AKC-4/AKC-4zo – Excise duty return (Appendix No. 1),
• AKC-4/M – Excise duty on e-cigarette liquid (Appendix No. 13),
• AKC-KZ – Quarterly excise duty return for excisable goods subject to excise duty exemption or a zero excise duty rate (Appendix No. 19).

Please be informed that, as of 1 April 2025, the Act of 24 January 2025 amending the Value Added Tax Act, the Excise Duty Act, and certain other laws came into effect. The amendment introduces significant changes to the VAT treatment of medical device supplies. These new regulations are particularly important for businesses in the healthcare sector, especially manufacturers, distributors, and healthcare providers.

No possibility to apply a transfer pricing adjustment under Article 11e of the CIT Act if the financial result falls within the arm’s length range of the benchmarking analysis - individual ruling of the Director of the National Revenue Information (KIS) of 8 November 2024, ref. nos. 0111-KDIB1-1.4010.535.2024.4.BS, 0111-KDIB3-3.4012.413.2024.6.AW

An end to suspending the limitation period upon initiation of Fiscal Penal Code proceedings? Ministry of Finance announcements