Europe

A landmark ruling by the Supreme Administrative Court, reported 28 October 2026, establishes that tax authorities may not dismiss witness testimony from employees of related entities merely because of their affiliation. The court held that corporate group ties alone do not undermine credibility, reinforcing procedural fairness in transfer pricing and controlled foreign company (CFC) audits.

On 28 October 2026, the Polish Ministry of Finance announced the conference “20 Years of APA in Poland,” scheduled for 17 November 2026. This milestone event commemorates two decades since Poland introduced Advance Pricing Agreements (APAs) into its transfer pricing framework, aligning with OECD guidelines and EU directives. The conference will gather tax authorities, multinational

The upcoming EU Customs Code reform, analyzed on 28 October 2026, shifts customs liability from consumers to digital platforms facilitating cross-border sales. Platforms will be required to declare goods, pay duties, and ensure compliance, ending the practice of passing obligations to buyers. This aligns with the EU’s e-commerce package and VAT e-commerce rules. Key Takeaways

On 28 October 2026, the National Revenue Administration (KAS) released its updated implementation plan for electronic services covering the period 2024-2028, current as of 30 September 2026. This roadmap details the phased deployment of new digital channels for tax and customs compliance, including enhanced e-declarations, real-time invoice exchange (KSeF expansion), automated VAT refund portals, and

In an interview published 28 October 2026, Katarzyna Krawicz-Nowak, Deputy Director of the Customs Department at the Polish Ministry of Finance, acknowledges that the EU customs reform is essential but flags unresolved issues regarding new digital sales models. Both businesses and customs administrations face significant adaptation challenges, including IT system upgrades and legal interpretation uncertainties.