Issues concerning taxes appear in most of commercial transactions. Consideration of tax implications may influence the form and method of conducting a particular deal. The team of our lawyers who specialize in tax law provides comprehensive advisory services concerning tax aspects of corporate, commercial and financial transactions.
We offer to our clients both assistance in tax matters connected with current operations and advisory services in tax proceedings and disputes, as well as wide-ranging advisory services concerning tax planning aimed at reduction of tax charges within the limits of valid law.
 
 
TAX CONSULTANCY

• Assessment of tax consequences of implemented restructuring projects, including splitting and merging of business firms, issuing of recommendations with consideration of tax consequences of such occurrences
• Presentation of opinions concerning agreements and commercial contracts, recommendation of optimum tax solutions
• Assistance concerning transborder transactions and avoidance of double taxation
• Preparation and assessment of transfer pricing documentation
• Advisory services concerning mechanisms of tax optimization for managers and key employees
• Advisory services concerning income tax, real estate tax, inheritance tax, VAT etc.
• Carrying out comprehensive due diligence legal audits preceding certain capital deals, which audits include tax matters
• Current advisory legal services concerning wide spectrum of tax matters

 
DISPUTES / TAX PROCEEDINGS

• Advisory services in pre-inspection period
• Advisory services during tax inspections and proceedings
• Preparation of objections and requests for fiscal penal inspection reports
• Preparation of appeals and complaints during tax proceedings
• Advisory services during proceedings to secure claims and enforcement proceedings in tax-related matters
• Preparation of complaints to administrative courts and cassations against judgements of voivodeship administrative courts and representation during proceedings initiated by lodging of such complaint/cassation
• Preparation of constitutional complaints in tax matters and representation before the Constitutional Tribunal
• Preparation of complaints to the European Commission in connection with non-compliance of Polish law regulations or judicial decisions practice with Community regulations
• Elaboration of matters concerning EU law for the purpose of current tax disputes, including drafting of prejudicial questions to the European Court of Justice
• Advisory services and representation in fiscal penal proceedings.

 
TAX PLANNING

• Identification of key areas influencing efficiency of tax settlements, taking into account such factors as differences in accounting and tax depreciations, differences concerning taxation moment, or specific exclusions from expenses eligible for taxation
• Preparation and implementation of solutions which optimize taxation, from most basic forms concerning appropriate managing of tax expense items, up to more sophisticated, covering items structuring taxpayer's assets and 'owners' equity and liabilities' and making use of opportunities offered by foreign tax jurisdictions
• Preparation and obtaining of binding tax interpretations in Poland and foreign jurisdictions
• Obtaining tax opinions and legal opinions of specialists in foreign jurisdictions, which participate in optimization measures
• Analysis of tax consequences of transactions planned by client, including in particular capital transactions and assessment of tax risks arising from them, and working out solutions so as to minimize such risks
• Assistance in setting up and managing of foreign legal vehicles (such as holdings, foundations) in a number of jurisdictions offering friendly tax solutions, including in particular in the Republic of Cyprus, Luxembourg, Liechtenstein, United Arab Emirates, Slovakia, Sweden, Switzerland, the Netherlands, Malta or British Virgin Islands
• Monitoring of and responding to planned tax-related changes and suggesting optimization solutions adequate to changing legal circumstances