The terminology issue regarding the concept of “privacy” seems to be increasingly important in the context of the changing tax reality in which the emphasis is put even more strongly than before on the protection of fiscal interest, at the expense of limiting the sphere of taxpayers' privacy, in particular through the expansion of their surveillance on an unprecedented scale.

The OECD, in its notable achievements, treats the taxpayer's right to privacy very superficially. In one of the documents, which is a kind of report on the rights and obligations of taxpayers in force in individual countries, we can read that “All taxpayers have the right to expect that the tax authorities will not intrude unnecessarily upon their privacy”. I would argue that this statement is far not enough in the reality of current technological possibilities and realizes too narrow protection of taxpayer’s right. The issue of taxpayers’ right to privacy should be introduced to public and scientific awareness. But how should the term privacy itself be understood? The answer is not easy, one the term is not precise so understanding is difficult though the literature on this issue is very broad. Two it is rarely used on the ground of debate on taxation. The critical approach has led to a review of the immensely rich body of literature on the theory of privacy and the right to privacy, and an attempt to adopt an understanding of the term “privacy” that will also be useful in tax matters. There is the absence of a consensus on the adoption of a particular way of defining “privacy”. For that reason it has to be emphasized that there is no theoretical basis to conduct a discussion on this specific taxpayer right, which is right to privacy. This paper is an attempt to find such understanding of the term "privacy" that will be useful in tax context.

The article aims to present the model of proceedings in the case of a financial penalty being imposed for infringement of banking law in Poland and Germany and verify whether the parties' right to defence is ensured. The above issue is extremely topical, especially in light of the number and amount of financial penalties imposed by banking supervisory authorities. The article's thesis assumes that the legal regulations in force in Poland and Germany make the indicated guarantee a reality. The article highlights the role of financial market supervisory authorities, whose activities, including the imposition of financial penalties, translate into the safety of the banking sector. Detecting and then sanctioning banking law violations motivates financial market participants not to commit such violations. First, based on an analysis of judicial decisions and international law norms, the criteria that an exemplary model implementing the principle of the right to defence should meet were established. On the other hand, the following part of the article compares the legal framework in Poland and Germany and verifies whether the legal provisions provide the parties with the guarantees in question when imposing a financial penalty for violations of banking law.

The growth in the use of Special Purpose Acquisition Companies (SPACs) within the context of the European market economy has been particularly evident in recent months. When structuring SPACs, the question of whether and when SPACs fulfil the objective criteria of the activities indicative of the characteristics of their specific management under the Alternative Investment Fund Managers Directive (AIFMD), arises. SPACs are, in fact, similar in their basics to the alternative investment funds established under this directive and whose investment strategy is directed towards private equity. The aim of this paper is to answer the presented question, which is crucial for current financial market practice. If the intended investment structure of SPACs fulfils the criteria of the AIFMD, it can only be structured under the rules (and restrictions) arising from respective regulations. Any misconduct is otherwise severely sanctioned.

The main aim of this contribution is to make a review and assess the application of BEPS Action 7 recommendations by the tax administration in Poland when determining whether a non-resident enterprise operating in Poland should be considered to have a permanent establishment (PE). The creation of a PE is crucial for taxable presence in Poland and for identifying the scope of the allocated revenues and expenses (taxable income). Changes to the OECD Model have a genuine practical impact on multinational enterprises and tax administrations and thus they need to be closely examined. The considerations serve to prove the hypothesis that Polish tax authorities apply the recommendations of BEPS Action 7 despite the fact that Poland lodged reservations concerning the non-application of Art. 12-14 of the MLI in its entirety. Beyond the legal-dogmatic research the contribution refers directly to the results of an empirical study carried out by the authors in the course of which 88 individual tax rulings issued by the Polish tax authorities were identified and examined.