Poland: Payment to achieve target profitability not subject to VAT; only one tax identification number required

Summaries of recent Supreme Administrative Court decisions

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February 11, 2025

The KPMG member firm in Poland prepared a report that includes summaries of the following decisions of the Supreme Administrative Court:

  • The court on February 5, 2025, held (case file I FSK 2452/21) that a payment to a related entity (a local distributor) to increase the distributor’s profitability to a target level did not constitute remuneration for distribution services, but rather was a transfer pricing adjustment, and thus was not subject to value added tax (VAT).
  • The court on January 30, 2025, held (case file III FSK 1274/24) that if an entity obtains a tax identification number under Article 2(1) of the Act on the Polish Tax Identification Number on account of acting as a taxable person, there is no need for such an entity to obtain another number under Article 2(1) of the Act merely because it also acts as a remitter.

Read the February 2025 report

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