Through tax planning, we select possible solutions in such a way that the client effectively pays the lowest possible taxes, following the principle: nowhere is it said that you have to choose those solutions for which the public and legal burden is the highest. We are flexible, which is why tax planning can cover the entire scope of a company's operations, its individual departments or a single transaction.
An announced, or worse, unannounced tax inspection is a stressful situation and an entrepreneur should focus on running his or her business. That is why we offer comprehensive tax support during a tax inspection, with the possibility of representing the client before the authorities conducting the inspection. We represent clients in tax proceedings and in proceedings before administrative courts. Based on our experience, we effectively defend the client's rights.. We know that the correct formulation of applications and letters in tax and fiscal proceedings as well as the use of tax procedure is of key importance for the successful completion of the inspection for the taxpayer.
Tax review is one of the most effective tax advisory instruments that brings real financial benefits.
The key objectives of the tax review are:
- identifying potential tax risks and then developing solutions to minimise or eliminate the risks;
- revealing untapped opportunities for optimising tax settlements.
A tax review may cover any period (monthly, quarterly annual, several years). Depending on the needs, the review may concern the entire tax system of the company, as well as refer to selected processes or transactions considered to be key.
We always produce a report from the tax review with specific recommendations for the company's next steps.
Documentation of transfer pricing
Enterprises transacting with related parties or partners joining partnerships over certain transaction amounts must prepare transfer pricing documentation and report it on the tax form.
Well-prepared transfer pricing documentation makes it possible to make the entrepreneur's tax burden more realistic, to adapt the company's business model to the legal requirements related to these issues, and to prepare the entrepreneur for possible inspections by the tax authorities.
The services we offer in this area include, in particular:
- an analysis of related party transactions, in particular an analysis of resources, functions and risks, as well as how transfer pricing documentation has been maintained to date;
- Preparation of transfer pricing documentation in accordance with applicable national legislation and OECD guidelines in this area;
- preparation of local filings for international groups;
- preparation of a study outlining the tax risks involved, ways to mitigate them or possible changes to the way in which transfer pricing documentation and risk management is carried out in the company, and the possible implementation of these proposals;
- representation in tax proceedings on matters relating to transfer pricing documentation.
Implementation and drafting of withholding tax procedures and indirect transactions with entities in tax havens
Recent regulatory changes have sealed the trend of shifting verification responsibilities from tax officials to taxpayers. It is now taxpayers who have to prove that they have the right not to withhold tax at source on foreign transfers for, among other things, payment for a service, a licence or trademark rights. This also applies to the transfer of domestic and foreign payments for purchases exceeding PLN 0.5 million during the year.
It sometimes happens that the tax authorities demand payment of tax on a purchase transaction in a situation where the law provides for an exemption or a reduced tax rate. Our law firm implements procedures to safeguard clients' interests against this type of conduct by the tax authorities.