Corporate income taxation

• On-going tax advice (recognition of expenses as tax deductible in time, etc.), tax opinions on planned operations, new agreements, etc.;
• Tax reviews – focused on identification of irregularities, optimization possibilities, procedural improvements;
• ax position planning and effective-tax-rate optimization – advice and planning with respect to tax depreciation, leasing, forms of financing, debt-to-equity, equity-to-debt (swap);
• Advisory related to one-off transactions - restructurings (mergers, contributions, hive-downs, transformations of legal form, etc.), structuring of sale transactions and financing;
• Optimisation of management compensation schemes (forms of employment for executives, stock option plans, etc.)

International taxation

Our extensive experience in the area of international taxation together with co-operation with our foreign business partners (in the EU and Asia) allow us to successfully support our clients in managing effectively income tax as well as other international tax burdens (capital taxes, fixed charges, VAT, etc.).

We see that more and more often, main aspects of advisory in corporate income taxes are cross-border issues. For this reason, we offer our assistance in the following areas:

• Taxpayer's security with respect to withholding tax on interests, dividends, licenses or services of intangible nature (recognition of payments for tax purposes, documentation requirements) and other issues related to foreign financing (cash-pooling, emission of foreign bonds, etc.);
• Using of foreign holding and finance companies and intellectual property management entities for purposes of optimizing the effective tax rate, and related aspects of such structures including day-to-day issues (taxation of flows, monitoring changes in different tax jurisdictions, etc.);
• Implications in Polish CIT and foreign income taxes resulting from carrying out business activity outside Poland – analysis of creation abroad of Permanent establishment for tax purposes (PE - permanent establishment), selection of the model of business activities, effective settlement of foreign taxes in Poland (foreign tax credits deduction in Poland, analysis of what part of income could be exempt, allocation of costs, etc.);
• Transfer pricing issues which in cross-border relations result usually in a broader scope of necessary analysis and documentation requirements; this is important also in the case of restructuring of business functions in the Polish entities related to multinational enterprises;;
• Tax management in capital groups, or even single entities performing various business operations, in particular cross-border transactions; we see that due to its dynamic nature, tax management in such cases gives rise to questions concerning effectiveness, adequacy of actions taken and possibility of optimising the whole business process.