Tax Advisory in Poland

What we do?

Ongoing Tax Advisory in Poland

We offer ongoing tax advisory services offer continuous, practical support tailored to the day-to-day needs of businesses operating in Poland. Below is a list of key services included in this offering:

• Resolution of Current Tax Issues – Support in addressing day-to-day tax problems arising during business operations.
• Tax Interpretation of Business Activities – Analysis of economic events and transactions to determine their tax implications.
• Review and Structuring of Contracts – Assessment of agreements for tax consequences and support in structuring contracts to align with tax goals.
• Development of Tax Strategies – Designing tax-efficient strategies for planned or ongoing business operations.
• Implementation Support – Assistance in executing tax strategies, including preparation of legal and tax documentation.
• Tax Risk Identification and Mitigation – Proactive identification of potential tax risks and advice on how to mitigate them.
• Written Tax Opinions – Formal tax opinions that clarify legal positions and aid decision-making.
• Ad-Hoc Consultations and Training – Meetings and workshops tailored to client needs to address specific tax questions and build internal knowledge.
• Direct Access to Experts (Tax Hotline Service) – Immediate access to tax advisors for real-time support on urgent tax matters.
• Monitoring of Tax Law Changes – Ongoing updates and analysis of changes in Polish and international tax regulations that may impact the business.
• Liaison with Polish Tax Authorities – Assistance in communication with tax offices, including support during audits and queries.
• International Tax Coordination – tax advisory services that consider cross-border operations and compliance with international tax standards (e.g., OECD, EU regulations).

Tax Compliance – Comprehensive Support

We provide full-spectrum tax compliance services covering all corporate areas that directly impact tax settlements and statutory reporting. Our goal is to ensure our clients’ tax obligations are met accurately, efficiently, and in full compliance with Polish regulations. Our support covers the following areas:

• Corporate Income Tax in Poland (CIT) – Full support with calculation, reporting, and filing of CIT obligations.
• Withholding Tax (WHT) – Assistance with correct application of WHT rules and reporting.
• Value Added Tax in Poland (VAT) – VAT settlements, filings, and tax advisory to ensure accurate VAT compliance.
• Civil Law Transactions Tax (PCC) – Handling of transactional tax obligations, including declaration and payment.
• Intrastat Declarations – Preparation and submission of statistical declarations for intra-EU trade.
• Transfer Pricing (TPR, CBC Reports) – Support in meeting obligations related to transfer pricing documentation and disclosures.
• Reports to the National Bank of Poland (NBP) – Filing of required reports on cross-border transactions and financial flows.

As a part of Polish tax compliance our services include:

• Taxpayer Registration in Poland – Support in registration processes for CIT and VAT in Poland.
• Calculation & Verification of Tax Liabilities – Accurate determination of tax due and review of internal tax calculations.
• Preparation and Submission of Tax Returns – Drafting and filing all relevant tax declarations, tailored to client-specific operations.
• Representation Before Tax Authorities – Acting on behalf of clients in dealings with tax offices and during tax audits or inspections.
• Tax Audits – Independent reviews of tax compliance in selected areas or across the entire company.
• Compliance Review & Risk Assessment – Evaluating the accuracy of tax settlements and identifying areas of potential risk.
• Drafting and Review of Tax Documentation – Preparation and assessment of all required tax documentation and disclosures.
• Tax Optimization Advisory – Guidance on legal opportunities to reduce the tax burden and improve overall efficiency.

Tax Advisory on Incentive in Poland

We provide advisory regarding tax incentives, in particular for new investors and international corporations entering Polish market. Our support covers the following tax incentives in Poland:

• R&D Relief – We assist in identifying eligible R&D activities, preparing documentation, and securing the deduction through proper filings and interpretations.
• IP Box – We help assess qualifying IP income, set up required tracking procedures, and apply the 5% CIT rate in line with tax authority expectations.
• Polish Investment Zone (PIZ) – We guide clients through the full PIZ application process, including business planning, document preparation, and authority negotiations.
• Prototype Relief – We advise on the eligibility of prototyping costs, ensure correct documentation, and assist in including the relief in your annual filings.
• Expansion Relief – We support clients in identifying eligible promotional activities, documenting expenses, and applying the relief correctly.
• Relief for Innovative Employees – We structure employee contracts and reporting to take advantage of reduced PIT advances for R&D personnel.
• Robotization Relief – We analyze investment plans, assess eligible expenditures, and guide clients through claiming the deduction securely.
• CSR Relief – We verify qualifying activities and ensure proper documentation for safe use of CSR-related tax deductions.
• IPO Relief – We assist in identifying and documenting IPO-related costs that qualify for deduction and ensure proper tax reporting.
• SEZ / Special Economic Zones – We handle SEZ qualification, permit applications, and post-grant compliance to secure and maintain tax exemption status.

Transfer Pricing Services

• Preparation of Transfer Pricing Documentation (Local and Master Files) – We compile comprehensive documentation to ensure compliance with Polish regulations and OECD guidelines.
• Adaptation of Existing Documentation to Polish Requirements – We review and adjust your current transfer pricing documents to align with Polish legal standards.
• Development and Implementation of Transfer Pricing Policies – We assist in creating and executing policies that govern intercompany transactions, ensuring consistency and compliance.
• Benchmarking Analyses – We conduct comparative studies to establish arm’s length pricing for your intercompany transactions.
• Verification of Transfer Pricing Activities – We assess your transfer pricing practices to identify and mitigate potential risks.
• Support During Tax Inspections and Proceedings – We provide expert assistance and representation in dealings with tax authorities concerning transfer pricing matters.
• Advance Pricing Agreements (APAs) – We guide you through the process of obtaining APAs to secure agreed-upon transfer pricing methods with tax authorities.
• Transfer Pricing Training and Workshops – We offer educational sessions to enhance your team’s understanding of transfer pricing regulations and best practices.

Tax Interpretations Services in Poland

•  Preparation of Requests for Tax Interpretations – drafting and submitting precise applications to KIS.
• Legal Review Before Submission – reviewing transactions to ensure clarity and relevance.
• Representation Before KIS – handling formal proceedings and correspondence.
• Challenging Unfavourable Interpretations – filing appeals or objections.
• Court Representation – representing clients in administrative court disputes.
• Advisory Based on Issued Interpretations – applying rulings in day-to-day operations.

Tax Due Diligence & Tax Advisory for M&A

• Corporate Income Tax (CIT) Due Diligence – assessment of the target’s CIT compliance and identification of historical and potential liabilities.
• Value Added Tax (VAT) Due Diligence – review of VAT settlements, returns, and transaction flows for compliance and risk exposure.
• Personal Income Tax (PIT) and Social Security (ZUS) Due Diligence – evaluation of payroll tax practices and related filings.
• Property Tax (PoN) and Civil Law Transactions Tax (PCC) Due Diligence – examination of obligations and past settlements for accuracy.
• Risk Identification and Assessment – identification of key tax risks in light of current tax law, interpretations, and administrative court rulings.
• Review of Tax Procedures and Controls – analysis of the internal procedures used for tax compliance and risk management.
• Tailored Due Diligence Reporting – preparation of clear, structured reports summarizing findings, risks, and red-flag issues.
• Tax Advisory Based on Findings – guidance on mitigation strategies, deal structuring considerations, and potential contractual protections.

International Tax Advisory Services

We provide strategic support to ensure international operations are tax-efficient, compliant, and protected from unnecessary risk.

• Double Taxation Relief Advisory – assisting clients in applying double tax treaties and abolition relief to minimize tax burdens.
• Beneficial Ownership Analysis – evaluating and documenting beneficial ownership status to comply with WHT and treaty benefits.
• Permanent Establishment (PE) Assessment – determining whether foreign operations constitute a PE in Poland and advising on implications.
• CFC Compliance Support – guiding clients through Controlled Foreign Company regulations to ensure proper reporting and taxation.
• Withholding Tax (WHT) Advisory – providing guidance on WHT obligations, exemptions, and the pay-and-refund mechanism.
• GAAR and SAAR Risk Assessment – analyzing transactions for potential challenges under General and Specific Anti-Avoidance Rules.
• Cross-Border Transaction Structuring – advising on tax-efficient structures for international business operations.
• Tax Residency Determination – assisting individuals and entities in establishing tax residency status in Poland.
• International Tax Dispute Resolution – representing clients in resolving cross-border tax disputes and negotiations with authorities.
• Advance Pricing Agreements (APAs) – supporting the negotiation and implementation of APAs to manage transfer pricing risks.

Tax Litigation in Poland and Tax Proceedings in Poland

• Representation in Tax Disputes – advocating for clients during tax audits, proceedings, and appeals before administrative courts.
• Defense in Fiscal Criminal Cases – providing legal support in cases involving allegations of tax crimes, from investigation through trial.
• Analysis of Tax Settlements and Overpayment Claims – reviewing tax calculations to identify errors and pursuing rightful refunds.
• Development of Tax Strategies – assisting in formulating compliant tax strategies and fulfilling related disclosure obligations.
• Mitigation of Criminal Liability Risks – advising management on practices to minimize exposure to fiscal criminal charges.
• Employee Training on Tax Compliance – conducting workshops to educate staff on tax laws and potential liabilities.

Tax Returns & Tax Reporting Services in Poland

• Preparation of Tax Returns – preparing and submitting accurate CIT, VAT, PIT, and other required tax declarations.
• Ongoing Tax Reporting Support – providing regular support with monthly, quarterly, and annual tax reporting obligations.
• Day-to-Day Tax Accounting – managing daily accounting operations with a focus on accurate tax compliance.
• Assistance in Tax Settlements – supporting clients in calculating and settling tax liabilities across various tax types.
• Review of Tax Calculations – verifying internally prepared tax data to ensure accuracy and compliance with current regulations.
• Communication with Tax Authorities – handling formal communication, clarifications, and responses on behalf of the client.
• Deadline Monitoring and Compliance Checks – ensuring all reporting and filing deadlines are met to avoid penalties.
• Advisory on Tax – Reporting Obligations – clarifying reporting requirements under Polish and international tax law.