• B2B Contract Audits – PIP May Alert the Tax Authorities

    B2B contract audits may not end with a decision issued by the Polish National Labour Inspectorate, or PIP. Information gathered by labour inspectors may also be shared with the tax authorities and the Social Insurance Institution, ZUS. This may lead to a review of the previous tax and social security settlements of both the company and the self-employed contractor.

    Rzeczpospolita published an article featuring our commentary on the tax consequences of reclassifying a B2B relationship as employment. The topic was also highlighted on the front page of the newspaper’s 7 July 2026 edition.

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  • B2B benefits as tax-deductible costs – tax authorities change their approach again

    B2B benefits as tax-deductible costs have once again become a disputed issue with the Polish tax authorities. In a recent article published by “Rzeczpospolita”, Piotr Sekulski, PhD, tax advisor at Outsourced.pl, comments on the change in the tax authorities’ approach to sports cards, medical packages and other benefits provided to B2B contractors. B2B benefits as […]

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  • Invoice for Company Management and Lump-Sum Taxation – Where Does the Risk Arise?

    An invoice for company management may seem like a simple optimisation tool, but in practice it often creates significant tax risks. Particular caution is needed where someone combines management functions with services provided to their own company through a sole proprietorship. We recently discussed this issue in a tax commentary published by Prawo.pl.

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  • Punitive 70% severance tax: the WSA in Gdańsk sides with the taxpayer

    The punitive 70% severance tax was intended as a tool to limit high severance packages in state-controlled companies. In practice, however, it is applied far more often than it should be—sometimes even to individuals who are not senior managers. What is more, taxpayers who have doubts increasingly cannot obtain a substantive individual tax ruling, because the Head of the National Revenue Information (Director of KIS) refuses to issue it right away. The refusal is justified by an “justified suspicion” of tax avoidance (Article 119a of the Polish Tax Ordinance). In a judgment of 15 October 2025, case no. I SA/Gd 626/25, the Voivodeship Administrative Court (WSA) in Gdańsk criticised this practice.

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  • B2B Reclassification into an Employment Contract: the PIP reform will not happen, but the risks for companies remain (2026)

    B2B reclassification into an employment contract – in early January 2026, the government announced that it would not continue the PIP reform aimed at strengthening the “administrative” reclassification of contracts. This does not mean a “green light” for any cooperation model: reclassifying B2B into an employment contract remains a real risk, because it depends mainly on how the work is actually performed in practice (not on what the contract is called).

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  • Online Sales Tax Audits Are on the Rise – What You Need to Know

    Online sales tax audits are becoming more frequent, especially with new DAC7 reporting obligations. More and more online sellers are receiving tax authority inquiries. What triggers an audit? How do you declare income from online sales correctly? What thresholds apply, and when do you risk being classified as running a business? In a recent article on Prawo.pl, Piotr Sekulski, PhD, comments on these growing risks.

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  • NSA: Invoicing Your Own Company May Indicate Tax Avoidance

    For some time now, tax authorities have been challenging B2B service arrangements provided by company board members to their own companies (commonly referred to as “invoicing your own company”) as potential aggressive tax planning. We have written about this issue before. The latest judgment of the Supreme Administrative Court (NSA) of November 5, 2024 (case ref. II FSK 996/24), confirms that such practices may raise a justified presumption of tax avoidance.

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  • Reclassification of a Mandate Contract and Its Impact on Personal Income Tax (PIT)

    Does the reclassification of a mandate contract by ZUS create a tax liability? How do the Polish tax authorities approach this issue, and is their interpretation favorable for taxpayers? Recently, the daily Rzeczpospolita published an article featuring a commentary by Piotr Sekulski PhD, a tax advisor, addressing this topic. Reclassification of a Mandate Contract by […]

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  • Prop Trading and Business Activity – What You Need to Know

    Prop trading and business activity. Proprietary trading – often called “prop trading” – has gained tremendous popularity in recent years. By allowing traders to operate with someone else’s capital, it removes one of the main barriers to entering financial markets: the lack of sufficient personal funds. That’s why prop trading is such an attractive option for many talented individuals looking to scale their operations. However, alongside the clear benefits, it’s crucial not to overlook the formal and legal aspects — especially when it comes to tax compliance. A key question arises: how should income from prop trading be classified under Polish tax law — as business activity or as income from personally performed services (e.g., under a contract for services)? This distinction has important tax implications. In this article, we explore that relationship — prop trading and business activity — in detail.

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