Polish tax law is subject to legislation changes on numerous occasions. tax regulations are often inconsistently interpreted by Polish tax authorities. Thus your tax settlements might impact significantly on your company’s fiscal policy and budget. We offer tax services that are aimed on increase of tax efficiency, however they allow to reduce tax exposures – i.e. to avoid misalignments between accounting, law and tax approaches, to reduce risk of tax outstanding, fiscal penalties and reputational risk.
Our tax advisory comprises of
- calculations of corporate income tax (CIT) on the basis of your P&L, calculation of personal income tax (PIT), value added tax (VAT), withholding tax (WHT), transfer tax (PCC) and real estate tax (RET)
- preparation of returns and tax statement that are required by the Polish tax regulations, including: VAT returns | CIT returns | WHT statements and returns | ECS lists | Intrastat reports for VAT on intra-Community trade
- keeping tax registers, including VAT registers
- on your request, we will conduct periodic CIT and / or VAT reviews (including assessment of VAT pro-rata factor). Identification of tax saving areas might be added-value of this periodic project.
Aims of ad-hoc tax review:
- comprehensive identification of tax risks in the selected period
- indication of the potential tax savings
- improvement of existing internal tax procedures
- identification of ideas that could be implement in order to minimize the revealed tax risks
Depending on your decision, our tax review might be performed in form of verification of complex tax position of your company or could be limited to selected tax area (i.a. to real estate tax or VAT). The review can also be limited to specific tax or accounting issues, depending on your business specific (i.a. review of marketing expenses policy).
We apply complex approach during tax review, as we do not limit only to tax matters – we highlight also accounting and legal issues that require improvement. Such approach positively distinguishes us from other consulting firms.
Awareness of Polish tax officers is constantly developing in the area of transfer pricing rules. Fraud detection in shifting incomes to foreign affiliates is one of the top priorities, that were set for the audits by the Polish Minister of Finance in 2014.
- mapping company’s transactions for the purpose of transfer pricing reporting requirements
- preparation of mandatory transfer pricing documentation in compliance with Polish regulations
- review and / or adaptation of existing intra-group documentation to Polish transfer pricing requirements
- assistance during tax audit and preparation of supporting documentation, if needed
Our services cover issues related to all the disputes with Polish fiscal authorities and before administrative courts, in matter of all the taxes present in Poland, including personal income tax (PIT), corporate income tax (CIT), value added tax (VAT), transfer tax (PCC), real tax and excise duty.
- professional preparation of tax rulings, formal motions and appeals
- representation in proceedings,
- professional assistance in tax audits and in appealing against an unfavorable standpoint of the tax authorities in other types of disputes
We offer professional assistance in the process of obtaining binding tax rulings issued by the Polish Minister of Finance. A favorable ruling is a valuable instrument in reducing tax burden and / or building tax optimization safety.
Representing taxpayers in disputes with the tax authorities and before tax courts
Taxpayers often fail to keep up with the latest amendments as Polish tax and fiscal law is subject to rapid changes. Often in practice, unclear tax regulations are construed by the tax authorities to a taxpayer’s disadvantage.
This results in high risk of non-compliance of the taxpayers actions with the requirements of the tax law.
We offer professional support in defending the interests of the taxpayer in wide range of disputes.
To whom we address our services?
- individuals conducting business activity in Poland
- shareholders of partnerships or companies
- expatriates seconded to work in Poland
- Polish nationals seconded to work outside Poland
- management and supervisory board members
- individuals, rewarded from copyrights, patents and other royalties - i.a. experts, programmers, analysts, employees of research institutes
Our portfolio covers the following services:
- shaping remuneration structures related to personal income tax and social security contributions, in particular through designing cost recharge structures between legal entities involved, preparing tax equalization calculations
- drafting policy for additional benefits for personnel, like company cars, mobile phones, pension schemes, healthcare, etc.
- support in obtaining E101 and other relevant certificates required by the social security regulations, including the Regulation (EC) No. 883/2004 of the European Parliament and of the Council and Regulation (EEC) No. 1408/71 of the Council as well as bilateral agreements concluded by Poland
We built up our experience in matters relating to tax aspects of international business over many years, providing services to clients (including investors from Germany) while working for the so-called Big-4 advisory firms, as well as for holding companies.
We supported Polish and foreign companies and their owners in a significant reduction of tax burdens, in improving financial results and streamline cash flows.
- tax advisory for branches of foreign entrepreneurs in Poland and assistance in registration formalities; structuring financial flows between permanent establishment and its foreign headquarter for tax and accounting purposes; VAT and CIT settlements, representation before the Polish tax authorities
- opinions on tax implications of cross-border trade and service transactions, transfers of royalties, distribution of capital gains: interest, dividends, etc.
- accounting and tax scenarios (CIT, PIT, VAT, transfer tax) for high-value asset deal | businesses; mergers and demergers. Support in implementation on all stages of the transaction
- designing tax and accounting optimization scenarios, in particular aiming tax and financial restructuring of holding companies (including cash flow advantages)
- tax planning, aimed at reducing tax burdens during restructuring of capital companies, partnership and family businesses. In this: projects aimed at achieving the benefits of the revaluation of assets for tax purposes
- tax and accounting analysis of transferred business for seller (i.e. tax vendors due diligence) | due diligence review for acquirer; share purchase agreement (SPA)
- Doradztwo podatkowe (CIT, VAT, PCC), rachunkowe i prawne w procesach sprzedaży i zakupu aktywów | przedsiębiorstwa, fuzji, podziałów i przejęć spółek - na wszelkich etapach transakcji
- planowanie podatkowe, ukierunkowane na obniżenie zobowiązań podatkowych w czasie restrukturyzacji spółek kapitałowych, osobowych i biznesów rodzinnych, jak i w okresie potransakcyjnym. W tym: projekty ukierunkowane na osiągnięcie korzyści z tytułu aktualizacji wyceny aktywów dla celów podatkowych
- analiza podatkowa, księgowa i prawna biznesu na potrzeby zbywcy (tzw. vendors tax due diligence) | na potrzeby inwestora (due diligence)
- analiza umów nabycia udziałów (SPA)
Nasze szkolenia indywidualne uwzględniają specyfikę obszaru działalności biznesowej naszych klientów, ze szczególnym uwzględnieniem zmian w polskich regulacjach VAT oraz CIT. Nowelizacje te weszły w życie z dniem 1 stycznia 2014 r. (tzw. Pakiet VAT / Pakiet CIT).