• 4 February 2026

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

    16:26 By InBusiness
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    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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  • 26 September 2025

    NSA: Invoicing Your Own Company May Indicate Tax Avoidance

    14:07 By InBusiness
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    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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  • 18 August 2025

    Punitive 70% Tax on Severance Payments

    15:09 By InGeneral rules
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    Although the 70% tax on severance payments was introduced to curb excessive payouts for senior executives in state-owned companies, today it is being applied much more broadly. Salary components paid to individuals with no connection to company boards – including mid-level technical managers – are often subject to this punitive flat rate. And when taxpayers request a tax ruling, the tax authorities refuse to issue one, suspecting an attempt at tax avoidance. Piotr Sekulski, PhD comments on the issue in his latest article for Prawo.pl.

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  • 17 January 2025

    Foreign Tax Establishment in Poland

    12:46 By InBusiness
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    Can business activity be classified as a foreign tax establishment in Poland?
    Does working remotely in IT create a foreign tax establishment? Could operating from Poland temporarily lead to tax consequences for sole proprietorships? These are the key questions explored in our latest analysis. In a recent article in Gazeta Wyborcza, our experts shared their insights on this topic.

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  • 10 December 2024

    Tax Implications of Swiss Franc Loans Settlements

    16:51 By InBusiness
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    Swiss franc loans settlements – new information has emerged regarding the tax implications of settlement agreements related to Swiss franc loans. Do all payments received under such agreements qualify for tax exemptions? What should you be cautious about when negotiating a settlement with a bank? How do tax authorities interpret the regulations? Recently, an article […]

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Piotr Sekulski, PhD

Doctor of Law (Jagiellonian University), author of numerous publications and scientific presentations. He collaborated with the universities of Buffalo (USA), Salzburg (Austria) and Heidelberg (Germany). As an expert on tax regulations at the Adam Smith Research Centre he participated in the preparation and evaluation of the regulations concerning entrepreneurs (e.g. e-meetings of shareholders). He gained professional experience in reputable tax advisory companies.

Blog Outsourced.pl

In response to numerous inquiries from our clients, we decided to launch a Tax Blog. We discuss current issues regarding the taxation of creative industries and the IT sector. Bearing in mind that that tax law, general law and accounting consist of hundreds of unclear and interrelated regulations, we try to organize the most important information and provide it in an accessible way.

We do not advise on the blog! This blog is supposed to be a source of information - however, each case should be approached individually. For a tax advice, please visit our website.

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