Publication date: April 29, 2025

Surreptitious advertising is a form of hidden promotion in which the advertising message is incorporated into editorial content, programs or social media posts without any clear indication that they are commercial in nature. When a famous person publishes a photo promoting a product or service for which they receive remuneration, but does not inform about the commercial nature of this content, it is covert advertising. Such practice can mislead the consumer, as they are not aware that the creator’s opinion is not entirely objective and they may be biased due to the fact that they received remuneration for the product review.

In the context of influencer marketing, this refers to a situation in which an influencer promotes products or services without clearly indicating that it is an advertisement, which may mislead recipients as to the nature of the content.

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Publication date: April 15, 2025

Exit fee is a fee for transferring assets, functions or risks between related entities. It can be understood as remuneration for the transfer of important functions, assets or risks. It is paid during business restructuring, either once or periodicall

On 30 January 2025 there has been issued important interpretation of the Director of the Polish National Revenue Information in respect of exit fee and tax consequences.

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Publication date: April 07, 2025

Payment for advertising and promotional services to a non-resident involves many tax issues that result from domestic regulations as well as international double taxation treaties (DTTs). To properly account for these payments, entrepreneurs must understand both the general rules on withholding tax and the provisions of international treaties that may affect the amount and principles of taxation.

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Publication date: March 31, 2025

Is CIT optimization by two companies in Dutch jurisdiction legal?

Legality in the light of Polish and international law

Market Principle and Transfer Pricing

According to Polish transfer pricing regulations (Articles 11a–11t of the CIT Act) and OECD guidelines, transactions between related entities must be agreed on arm’s length terms principle. If the tax authorities consider that transactions between a Polish and a Dutch company are not arm’s length, they may:

• Estimate the income of the Polish company and impose outstanding CIT.
• Impose a penalty tax rate (50% CIT – Article 19, Section 4 of the CIT Act).
• Apply criminal and fiscal sanctions against the company’s management.

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Publication date: February 19, 2025

Employers often address the question whether it is legal and possible to end employment relationship with the employee and enter into civil law relationship or B2B contract.

This article presents possibilities, risks and limitations of replacing employment contract with civil law contract.

At the outset, it is worth paying attention to the legal provision of the Polish Labour Code, namely Article 22 § 1, which states that:

“§ 1. By entering into an employment relationship, the employee undertakes to perform work of a specified type for the employer and under his supervision and at the place and time designated by the employer, and the employer undertakes to employ the employee for remuneration.”

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