International taxes

Cross-border issues and transfer pricing 

We notice that cross-border issues are increasingly becoming the major fields of CIT advisory services – therefore, we offer our assistance in terms of the aspects such as: 

WHT:

  • Securing the taxpayer of withholding tax (on interest, dividends, licenses and intangible services);
  • verification of possibility for the use of exemptions and reliefs resulting from EU Directives and international agreements; 
  • documentation requirements
  • other aspects related to foreign financing (cash-pooling, issue of foreign bonds); 
  • WHT procedure; 
  • Opinions on utilization of WHT preferences; 
  • Refund of WHT overpayment. 
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Foreign activity: 

  • Implications of running business activity abroad for the Polish CIT tax;
  • Analysis of issues related to so-called permanent establishment (PE) abroad; 
  • Transactions between foreign PE and Polish company; 
  • Effective settlement of foreign taxes in Poland (deduction in Poland, analysis which part of revenues can be subject to exemption, cost allocation, etc.); 
  • Tax on income from unrealized profits (Exit Tax). 

We also operate in the field of:

  • Advisory in terms of cross-border capital transactions; 
  • Assistance in terms of settlement of tax due on income of controlled foreign corporations (CFC) and on shifted profits; 
  • Analysis of obligations related to global top-up tax (income inclusion rule – IIR); 
  • Issues connected with transfer pricing also in the light of 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