International taxes

Cross-border issues and transfer pricing 

We have noticed that cross-border problems are increasingly becoming the most important areas of CIT consulting. Therefore, we offer our assistance in such aspects as:

WHT:

  • ensuring the taxpayer’s compliance with withholding tax (on interest, dividends, licenses, and intangible services)
  • verifying the possibility of using exemptions and reliefs resulting from EU directives and international treaties
  • meeting documentation requirements
  • managing various aspects related to foreign financing (cash pooling, issuance of foreign bonds)
  • handling WHT procedures
  • drafting opinions on the use of WHT preferences
  • facilitating the refund of WHT overpayments
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Foreign activity:

  • analyzing the effects of conducting business activities abroad on the Polish CIT
  • examining issues related to the so-called permanent establishment (PE) abroad 
  • managing transactions between foreign PE and Polish companies
  • effectively managing foreign taxes in Poland (deduction in Poland, analysis of what part of income can be exempt, cost allocation, etc.)
  • handling taxes on income from unrealized gain (Exit Tax)

We also operate in the field of:

  • providing advice on cross-border capital transactions
  • assisting with the tax settlement due on the income of Controlled Foreign Corporations (CFC) and on the profits transferred
  • analyzing obligations related to global top-up tax (the Income Inclusion Rule – IIR)
  • addressing transfer pricing issues, including restructuring business functions of Polish subsidiaries of international corporations/concerns

Do you need someone who carefully analyzes, checks carefully and looks for a solution until he finds it?

contact us