Tax

Tax advisory on transactions involving the sale and purchase of shares, businesses and assets covers:

• assessment of the tax implications of investments and ventures carried out,
• assistance with developing tax effective investment strategies, financing models and capital and business restructuring scenarios,
• transaction advisory covering due diligence, transaction structuring, analysis of transaction documentation and tax advisory during integration,
• advisory on taxation of management and key personnel in connection with a planned investment or restructuring,
• tax structuring of investments carried out by a public-private partnership and preparation of investments in SEZ.

At the tax planning stage we take into account not only tax implications but also legal effects and restrictions and key accounting aspects. As regards tax planning for both day-to-day and one-off operations, we offer:

• development and implementation of plans to manage tax liabilities, and support in mitigating tax risks and building up long-term tax strategies,
• support in preparing business reasons for reorganisation and transactions,
• structuring of assets and business activity of individuals in terms of safeguarding private assets, succession planning and risk management,
• structuring using Polish and foreign commercial companies and investment funds,
• preparing internal tax settlement procedures to mitigate the risk of criminal fiscal liability.

As regards tax cases and disputes we advise at every stage of the proceedings and our experience enables us to plan operations while optimising tax and facilitating a defence in the event of tax proceedings. We offer:

• pre-inspection taxpayer preparation for tax or customs inspections,
• advice during inspections and tax and customs proceedings,
• preparation of reservations to tax inspection reports, appeals against decisions, appeals against tax and customs authority decisions,
• comprehensive services in injunction and enforcement proceedings in tax-related matters,
• preparation of appeals to voivodship administrative courts and appeals against judgments passed by voivodship administrative courts in tax cases and court representation,
• preparation of constitutional appeals in tax cases and representation at the Constitutional Tribunal,
• preparation of appeals to the European Commission over incompliance of Polish provisions or judicial practice with Community provisions,
• development of EU law issues for the purpose of pending tax disputes, including drawing up draft questions to the European Court of Justice,
• full-range services in tax crime proceedings.

We also provide ongoing tax advisory services which include e.g.:

• support in reporting and paying corporate income taxes of companies,
• support in reporting and paying tax liabilities in connection with engaging employees and contractors,
• implementation and practical application of tax reliefs,
• VAT and excise tax reporting and payments,
• advice on transfer pricing in transactions between related parties,
• support in fulfilment of transfer pricing obligations, such as preparing transfer pricing documentation and TPR returns.