SERVICES

Tax audits

Ongoing tax advisory service

Services/Specializations

Tax proceedings

Individual interpretations

Tax optimization

Restructuring and M&A

Transfer pricing

Real property tax

Managerial contracts and bonus systems

Solutions for employers

Tax training

NGO & Scientific institutes

Accounting advisory services

Tax audits

The tax audit is an important and efficient tool of the company’s tax risk management.

Within the framework of our advisory services consisting in tax audits, we carry out tax audit to optimize tax settlements, aimed at finding hidden reserves of tax savings and improvements in the process of calculation of due taxes.

Our tax audits can also aim at identification of tax risks at ongoing tax settlements of business entities. We offer in this respect both full audits involving the detailed examination of the whole fiscal documentation, and tax audits based on the examination of a sample of source documents and of the most important items of the tax liability calculation.

There is a separate type of tax audits, namely dedicated examination, pre-purchase due diligence examination or investment audits to verify the tax settlement in selected areas of business particularly exposed to tax risks or involving assets of material value.

To date, members of the Law Firm team have carried out within the framework of activities and among other audits:

  • tax audit of an entity with foreign interest, one of the leading manufacturers of packaging, to search sources of tax savings in respect of income taxes and goods and services tax;
  • tax audit in respect of income taxes and goods and services tax at an entity dealing with one of the biggest sports-related investments of the last 25 years;
  • tax audit in respect of income taxes, VAT and civil transactions tax with an entity - one of the leading developers of financial and accounting software on the European market;
  • tax audit in a media house in respect of personal income tax and goods and services tax;
  • tax audit in respect of corporate income tax and VAT with an entity - one of the largest construction material distributors.

Members of the Law Firm team also took part in tax audits with the largest Polish enterprises in the energy industry, in banks and financial institutions, at manufacturers’ and many others.

Ongoing tax advisory service

Providing tax advisory services to our Clients, we have uninterruptedly rendered for more than ten years ongoing tax advisory services by way of phone and email consultations in ongoing issues of tax settlements, by way of issuing tax opinions in writing, opinions about contracts and preparing internal documents to affect tax settlements (by-laws, various types of policies in respect of particular tax issues, employment-related contracts, etc.). We support our Clients in contract negotiation process both with external entities and organizations acting in capital group internal structures.

We regularly provide our services to several dozens of entities operating in many industries. This lets us both acquaint with the vast array of practical tax and commercial issues and design effective solutions.

We always set to ourselves a main goal to understand our Clients’ business so as to be able to read their needs in tax and legal consulting before they become a burning issue. The regular cooperation we propose both in the form of the lump sum and the ongoing (project) settlement lets us get to know and understand our Clients better to provide much better services to them.

The experienced team of specialists lets us offer our Clients the ongoing service in income taxes, good and services tax, excise tax, real property tax and other local taxes and charges, tax on betting and gambling and in obligations concerning social and health security tax (contributions).

Services/Specializations

The long-time expertise of the Law Firm Founders and legal counsels and tax advisors cooperating with our Law Firm lets us render advisory services within many areas of tax law on a high competence level. Advising our Clients, we make use of this expertise, sharing it at each stage of project preparation and implementation.

Drawing on the experience of the long-time professional practice, we aim that our advisory services have, first of all, their measurable practical effect on our Client’s activity. Also the flexibility at approaching practical challenges faced by our Clients is our priority. With our long-time experience, we yet do not follow beaten tracks, but we take on inventive and original solutions, which let us offer always up-to-date and client-tailored services.

At the same time, we take care of the security of solutions we suggest. We provide full support to our Clients, not only at the stage of project preparation and implementation, but also later, for the whole period of work of the solutions prepared by us.

Tax proceedings

Our Law Firm has above-average competence in tax proceedings, coming from rich experience in trials. We can also be proud of many successes, successfully closed disputes between our Clients and tax authorities. Depending on a situation concerned, we involve in conducting our Client’s cases already at the stage of the tax investigation, because then evidentiary material is collected as a basis for further proceedings. The content of that material is often a decisive factor of success or loss in the pending dispute. However, even when accepting a case at the stage of proceedings before administrative court, we often achieve a success, having our share in the formation of the jurisdiction approach by precedent-setting rulings of the Supreme Administrative Court.

Representing our Clients during tax inspection proceedings, we make use of the designed for many years models of effective proceedings and harmonious cooperation with tax authority representatives.

In their practice to date, members of the Law Firm team have obtained many times rulings advantageous for the represented Clients bringing measurable financial effects, not so rarely expressed in multi-million tax amounts. In many cases, advantageous rulings were made during proceedings pending before tax authorities. In their practice to date, members of the Law Firm team have achieved a success in proceedings in cases such as:

  • taxation on income from lease of commercial real properties and settlement of renovation costs;
  • numerous cases concerning corporate and personal income tax liabilities as a consequence of tax investigation; they caused that proceedings were closed by repealing decisions issued by tax authorities (tax investigation);
  • determination of taxpayer’s income in transactions with affiliates;
  • tax settlements of participants of restructuring transactions connected with transfer of an organized part of an enterprise.

Individual interpretations

Aiming at safeguarding to our Clients the tax security of their actions, we offer also comprehensive assistance in preparing tax law interpretation requests, including both preparing the question content and representing the Client in proceedings for issuing the interpretation before tax authorities and administrative courts in case of the need to appeal against a tax interpretation adverse for the Client.

On behalf of our Clients, we obtained many advantageous individual interpretations providing tax security in ongoing tax settlements, also having as a goal obtaining by our Clients material tax savings in their transactions.

As an example, we mention below certain proceedings conducted by our Law Firm to have tax interpretations issued:

determination of the tax consequences of implementation of motivation programs based on use of derivatives (phantom stocks);

  • tax classification of a set of property components being a subject matter of restructuring actions in a capital group, as an organized part of an enterprise;
  • determination of the amount of the deductible costs connected with the settlement of the positive goodwill;
  • settlement of the VAT liability by health services providers to the National Health Fund;
  • applying tax exemption by foundations within the framework of achieving the objectives provided for in their statutes;
  • tax neutrality of actions connected with scheduled tax structures that aimed at sale of or enterprises restructuring.

Tax optimization

Providing our tax advisory services in tax optimization, as the first step it is necessary for us to acquaint with the goal the taxpayer would like to achieve: whether preparing its enterprise for sale and sale of it, transferring it to its successors or making a single transaction on company’s property, etc. The optimization solutions we suggest to our Clients are always personalized and client-tailored. We aim that the optimization solutions we suggest be as effective and safeguard the tax security to as wide extent as possible.

We regularly collaborate with partners proven on the Polish and international market. This gives us a chance for offering wide range of solutions and implementing these solutions uniformly and consequently, whether they concern national entities or require actions under foreign tax jurisdictions.

We are guided by the highest ethical standards in our actions. The solutions we suggest are lawful.

Members of our Law Firm participated in planning and implemented optimization projects such as:

  • projects connected with use of the tax value of trademarks;
  • projects giving an opportunity to make use of retained earnings of enterprises in various legal and organizational forms;
  • projects concerning sale of enterprises, shares in companies or selected fixed assets components using national and foreign tax structures;
  • projects aiming at optimization of the amount and moment of taxation on revenue on the daily business.

Restructuring and M&A

We provide full support in processes of the financial and organizational enterprise restructuring, both in the legal area connected with corporate actions to be taken, and in the tax area.

We implement in comprehensive projects involving:

  • transactions of acquisition and sale of shares in companies;
  • transfer of in-kind-contributions, including those in the form of an enterprise or an organized part of an enterprise;
  • transformations, mergers and divisions of partnerships and companies;
  • cross-border transactions.


On the grounds of their long-time and diversified experience, members of our Law Firm team perfectly know the unique nature of operations of many industries. To understand our Client’s needs is a key to the success of the pending restructuring. This is why we spend so much time on learning the needs and expectations of our Clients and the opportunities taking place in their individual situations, precisely to achieve that the scheduled restructuring actions be finalized with success.

Transfer pricing

We provide full support to our Clients in the appropriate performance of tax obligations connected with documenting transactions with affiliates. In preceding years, the area of transfer pricing is a branch of tax law being amended dynamically, and these amendments generally aim at broadening the substantive and objective scope of situations, which require both analyzing whether or not transactions are on an arm’s length basis and drawing up the transaction-related tax documentation.

We offer full support in transfer pricing, starting on identification of affiliates in the tax-related understanding and of transactions being a subject of special severe transfer pricing requirements. We draw up transaction tax documentation according to statutory requirements, both for individual transactions concerned and as model documentation for repeating or continuous transactions.

We also advise in the transfer pricing policy in capital groups. We draw up and verify use of the Master File documentation. We prepare comprehensive instructions, customized to the Client’s individual and capital group’s organizational structure, on how to carry out obligations in the transfer pricing area. We also cooperate with experts in economy to prepare benchmarking analyses for the needs of drawing up special tax documentations.

Recently, members of the Law Firm Team implemented the following transfer pricing projects:

  • full transfer pricing documentation for all transactions in a capital group involving totally more than 100 separate types of services/transactions;
  • instructions on how to carry out transfer pricing obligations for a large entity of the hotel and spa industry;
  • analysis of use of the Master File documentation for a branch office of an international manufacturing corporation.

Real property tax

Members of the Law Firm team have also rich experience in tax advisory area involving the real property tax, achieved at implementation of projects for the biggest energy or construction industry companies, for which the real property tax is a material cost item. Due to the unique nature of such tribute as the real property tax, where there is a lot of tax authorities entitled to collect it, to settle the tax appropriately is often a real challenge for the taxpayer. The practice shows that in order to classify the taxpayer’s property appropriately for the needs of taxation with the real property tax, the knowledge of the Local Taxes and Charges Act as such is not enough. The knowledge of other branches of law and rich judicature of tax authorities and administrative courts is also required. Implementing real property tax projects, we have the foregoing in mind. The solutions we suggest give our Clients security and notable effects: optimization of settlements, minimization of the tax risk and won court cases.

The real property tax projects implemented by members of the Law Firm team have included to date:

  • wide-range assistance at real property tax settlements, including support in classification of particular property components to be taxed with the real property tax;
  • tax audits to identify the tax risk as well as showing potential savings areas in respect of local taxes;
  • disputes pending on the tax authorities level (municipality or city mayor, president) as well as before administrative courts, including the Supreme Administrative Court in Warsaw.

Motivation systems

Advising our Clients in tax matters, we often face a need to design a motivation system optimal in the tax aspect for both our Clients’ employees and contracting parties. Aiming at providing comprehensive solutions, we draft by-laws and benefit policies optimal as regards tax consequences for both a motivation solutions provider and beneficiaries of those solutions.

Within the framework of the aforesaid practice, members of the Law Firm:

  • developed and implemented optimal and tax-secured solutions for company car policies;
  • developed and implemented motivation programs based on derivatives (options, phantom stocks);
  • developed rules of promotion events (bonus sales, contests) providing tax-optimal ways of motivating employees and contracting parties of our Clients.

Solutions for employers

Providing our tax advising services, we focus also on issues relating to the appropriate performance of personal income taxpayer’s obligations and to payment of social security tax (contribution). The proper classification of the paid or transferred amount is sometimes difficult and requires the knowledge of the recent tax judicature due to the changeable approach of tax authorities and courts to amounts concerned. Within the scope of our tax advising services dedicated to employers we try to provide tax-secured solutions, at the same time bringing real savings for both an employer and an employee. The projects implemented by our Law Firm included first of all:

  • classification of paid amounts to be reported as appropriate revenue source;
  • assessment of whether or not the determination of the base of tax and ZUS contributions calculation was correct;
  • developing managerial staff remuneration systems optimal as regards taxes and ZUS charges, based on structures of payroll distribution to minimize tax burdens both on the taxpayer and the withholding agent.

Tax training

Sharing our knowledge in tax law theory and in tax law in action is a vital element of our Law Firm activity. As trainers, we prepare, organize and conduct trainings and seminars in tax law. We cooperate with leading scientific and training centers, contributing to their offer of education for accounting and tax departments of enterprises and for individual students.

We also prepare thematic trainings and workshops as ordered by our Clients in specified, selected practical issues of tax law. We offer full support in selecting the topic, preparing teaching material, training material and carrying out training or workshop in a selected location.

As an example, trainings provided by members of our Law Firm concerned:

  • changes in income taxes, goods and services tax and excise duty;
  • settlement of the goods and services tax by medical entities;
  • taxation on scientific institutes with income tax;
  • settlement of claims for the needs of taxation (write-offs, receivables redeemed, overdue debts)

and many other topics.

NGO & Scientific institutes

Cooperation with scientific institutes is a material element of our Law Firm activity. Because of their special legal status and separate regulations for their activities connected with that status, in practice, scientific units face many tax issues not existing at other taxpayers’ and in other industries. Thanks to our long-time close cooperation with many institutes, advisors, who compose the Law Firm team, have knowledge and tools to eliminate efficiently and, first of all, effectively any tax exposure coming into existence.

Cooperation with foundations, associations and other entities acting pursuant to their statutes for public benefit is also a vital element of our Law Firm works. Here we have unique expertise in tax advisory services and in resolving issues of taxation of corporate income tax-exempt entities. The unique nature of tax settlements in designation of earned income for the objectives provided for in statutes causes that the appropriate performance of tax obligations by such entities is rarely without doubts and tax risks coming from such doubts.




Members of our Law Firm team have advised to such entities for many years, providing tax advisory services to them in the form of ongoing advising, tax audits, trainings and as legal representatives in court proceedings, efficiently proving the tax settlements of such entities to have been correct.

Accounting advisory services

Aiming at providing our Clients the comprehensive service in tax settlements, the Law Firm regularly cooperates with entities experienced in keeping books and with chartered accountants in matters of auditing financial statements and in difficult accounting issues connected with correct recognizing particular events in books.

We search for original solutions,
because we listen to what our Client's need

Trust and security
We build value-based relations

Our teamwork
for our Client’s success