Tax in Poland
Baker & McKenzie Krzyżowski i Wspólnicy Spółka Komandytowa's team comprises tax advisers, lawyers and economists, allowing it to advise clients on the full spectrum of tax matters. Under the leadership of Sławomir Boruc, the group is noted for litigation in relation to VAT and corporate tax work, as well as excise matters. On the advisory front, the group routinely handles cross-border restructurings and general tax optimisations, in addition to transfer pricing advice (an area where counsel Tomasz Chentosz takes the lead). Transactional work is another key area, and the group has a strong track record assisting with real estate deals and M&A projects.
‘The tax team is extremely professional, reactive and has a very good knowledge of our company’s business and history that is fundamental in order to structure the work in the most efficient way.‘
‘Knowledge and understanding of how the business runs – this is unique. Detailed oriented, proactive in finding solutions and very professional attitude.‘
‘Open to listen and understand, creative thinking and problem-solving type of approach.‘
‘Tomasz Chentosz is extremely competent, has an extraordinary knowledge of our company and business, he always proactively indicates potential risks or areas of attention and proposes effective solutions. His way of working inspires complete trust.‘
Generali Real Estate
Atrium European Real Estate
- Provided comprehensive tax assistance to Generali Real Estate on its acquisition of a prime office building in Warsaw – ‘Plac Malachowskiego’.
- Advised one of the world’s leading providers of financial services to institutional investors on the right to the recovery of input VAT.
- Advised on a reorganisation aimed at tax migration of companies and assets held by a wealthy family to Poland under the umbrella of a family foundation.
CMS Cameron McKenna Nabarro Olswang Pośniak i Bejm sp.k.
CMS' main areas of expertise comprise tax structuring, transactional tax, transfer pricing and tax disputes; it also handles warranty and indemnity insurance transactions. The group also handles cross-border tax advice, drawing on the firm's strong presence across Europe. The client roster includes private equity funds and corporates in the real estate and construction, financial services, energy and consumer goods industries. Appointed managing partner in 2019, Andrzej Pośniak leads the department and the firm's CEE tax offering, and co-leads the global tax group. Newly promoted partner Łukasz Dynysiuk specialises in tax planning and structures, as well as the tax aspects of M&A. Senior associate Paulina Karpińska-Huzior has experience representing clients in tax proceedings before administrative authorities, and in penal fiscal proceedings before state enforcement authorities.
‘Top expertise; business-oriented, solution-driven, capacity, leadership. Top tax practice in Poland.‘
‘Andrzej Pośniak is extremely client focused in everything that he does, and with a strong understanding of our commercial objectives and goes the extra mile to support us.‘
‘Quick, accurate and also friendly and with low stress level.‘
‘Piotr Nowicki stands out for client care and structured advice and training tailored to business needs.‘
Mid Europa Partners
CVC Capital Partners
Bank Polski Kasa Opieki
- Advised PDH from Grupa Azoty, the key Polish player in chemical sector, on tax issues relating to the first propane dehydrogenation (PDH) and polypropylene production (PP) installation in this part of Europe.
- Advised Pierre Fabre on the launch of its first online store in Europe.
- Advised RE Investment, a Luxembourg real estate fund, on the tax aspects of the sale of real estate located in Warsaw at Kasprzaka street to A&O Hostels.
The tax team at Dentons is jointly led by transactional and contentious tax expert Karina Furga-Dabrowska and Cezary Przygodzki, who focuses on tax advisory issues, international tax planning work and M&A structuring. It is noted for its expertise in tax issues relating to highly regulated sectors, particularly for financial institutions, private equity houses and energy companies, in addition to real estate sector clients. For cross-border work, the group is regularly instructed on transaction support issues, tax reviews, transfer pricing work and tax structurings. Michał Turczyk leads on development and innovation grants and incentives.
Cogito Capital Partners
Brand New Galaxy
- Advising Orbis, the largest hotel group in Central Europe, on the separation of its real estate ownership activity from its service business, and on the subsequent sale of its service business to Accor.
- Advising BNP Paribas Bank Polska on the carve-out of its factoring activity and its subsequent sale to BGŻ BNP Paribas Faktoring.
- Representing energy sector clients in numerous court proceedings with respect to the real estate tax imposed on wind farms.
Domanski Zakrzewski Palinka's tax department consists of lawyers and tax advisers, with substantial experience in M&A, restructuring and tax optimisation work, as well as representing clients in tax proceedings and assisting with issues surrounding tax inspections. The group advises a mixture of private clients, corporates and private equity houses and is jointly led by transactional tax specialist Joanna Wierzejska and Artur Nowak, who is an expert in tax and customs law litigation.
‘The diversity and many years of experience of the team members makes it very versatile and in that sense unique.’
‘My team likes to cooperate with DZP, because we are sure of the quality of services provided and at the same time the team is very cooperative, you can even say friendly in cooperation.’
‘Professional, well known firm in Poland, wide range.’
GWW's strength lies in tax litigation, an area in which managing partner Andrzej Ladziński takes the lead, while also advising on mandatory disclosure requirements. Artur Cmoch heads up the international tax planning work, predominantly acting for businesses in the real estate and telecoms industries.
‘Very responsive, different disciplines of law in various jurisdictions, the service is on the highest level for a reasonable price.‘
USP Zdrowie / US Pharmacia
Fabryka Mebli Biurowych Forte
Hogan Lovells (Warszawa) LLP's team regularly works with the firm's other departments, advising on the spectrum of transactional tax matters, as well as supporting the firm's offices in other jurisdictions with cross-border matters. Andrzej Dębiec leads the department, and is an expert in optimisation projects, tax planning and M&A structuring work, and has experience handling disputes before the Polish tax authorities and courts. Counsels Zbigniew Marczyk and Dorota Walerjan are qualified tax advisers; Marczyk focuses on the tax aspects of securitisation transactions, and Walerjan specialises in issues arising from the insurance and banking sectors.
‘In the area of tax issues, but also banking solutions and corporate issues, Hogan Lovells is far in front of their competitors. They have quality, expertise, full coverage of subjects and unlike others they provide solutions, complete and in time.‘
‘Exceptional work quality based on the broad international experience and professional knowledge presented by Andrzej Dębiec.‘
Astaldi SpA Oddział w Polsce
Bank BNP Paribas
Bank PKO BP
- Advising ABC Group on the tax aspects of selling ABC Data to ALSO Holding.
- Providing tax services to the mBank group on an ongoing basis.
- Advising companies in the BNP Paribas group in Poland on tax related matters with respect to investment and restructuring projects.
Demonstrating 'considerable experience' and an 'ability to define problems and identify potential risks', the team at Olesinski & Wspolnicy handles the full spectrum of contentious and non-contentious tax issues. Most notably, it is often called upon to support domestic and cross-border transactions, handling large-scale M&A and restructuring projects, as well as transfer pricing issues. Lawyers are also experienced in tax litigation. Tax advisory specialist Tomasz Gałka leads the team alongside international tax expert Wojciech Fryze.
‘The team presents high integrity and often creates a feeling like they work as one. They always care about continuity of service.‘
‘Tailor made solutions combined with local to-the-ground understanding of the local market. Comparing to other firms, knowledge of local industry reality is a positive, distinguishing element. Plus quality on international level.‘
‘Wojciech Fryze is an expert with deep knowledge and practical understanding of the company’s needs.‘
GKN Driveline Polska
Hengst Filtration Poland
SRG Global Bolesławiec
Volkswagen Motor Polska
BNY Mellon (Poland)
Maruta Wachta Sp.J.
Bombardier Transportation Polska
Hengst Filter Polska
- Advised a company on the tax aspects of establishing cooperation with an insurance company within a project of extended warranty insurance.
- Successfully appealed a tax ruling concerning withheld tax before a provincial administrative court.
The tax department at Radzikowski, Szubielska i Wspólnicy sp.k., under the leadership of Dorota Szubielska, focuses on tax litigation, representing clients including banks, investment funds, real estate developers and energy and manufacturing companies in a range of disputes before the Polish courts and tax administrators. The group also specialises in contentious direct and indirect tax issues. Piotr Karwat has expertise in fiscal control and tax proceedings, including administrative and court proceedings.
‘We work closely with Dorota Szubielska, one of the best tax lawyers in Poland. We feel in good hands here and are really grateful for such exceptional results.‘
‘Unique composition of law knowledge and practice. Perfect communication skills. Creativity and flexibility.‘
Fabryka Samochodów Osobowych
Look Finansowanie Inwestycji Łukasiewicz i Wspólnicy
- Represented a Polish businessman in a claim before the Constitutional Tribunal and Supreme Administrative Court, successfully winning a tax refund.
- Successfully represented EDP Renewables Group in a case before the Provincial Administrative Court in Olsztyn regarding real estate tax in the context of a wind farm.
Soltysinski Kawecki & Szlezak's standalone tax, customs and foreign exchange department is experienced in all areas of tax. It has particular expertise in representing clients before the tax authorities and courts, tax planning and implementation matters, tax audits and transfer pricing work, as well as contentious and non-contentious VAT issues and wealth tax management mandates. Transactional tax specialist Jarosław Bieroński leads the team, which includes 'recognised expert' in international tax law Sławomir Łuczak.
‘They have an outstanding knowledge of not only Polish tax and legal laws, however, also of international developments affecting clients in general.‘
‘Sławomir Łuczak is extremely good technically. He really understands international tax aspects and how a transaction needs to be carried out.‘
‘The tax team is commercial and flexible, covering a broad range of transactions with good insight.‘
ING Bank Śląski
ING Bank Hipoteczny
Solaris Coach & Bus
Ares European Property Enhancement Partners II, LP
Dębica Firma Oponiarska
- Advised ING Bank Hipoteczny on the development and implementation of a tax efficient strategy for the purchase of a portfolio of mortgage loan receivables to be used to issue mortgage covered bonds.
- Advised Sokołów on the preparation, negotiation and implementation of a tax efficient scheme of share and asset purchase transactions involving the acquisition of Gzella Group’s businesses.
- Obtained a positive judgement from the Voivodship Administrative Court in Kielce for Infover in a complex case concerning participation in a so-called VAT carousel.
Wardynski & Partners
Wardynski & Partners stands out for transactional tax issues, noted for its M&A and restructuring advice, international tax work for inbound and outbound investors, issues relating to new technologies, and private client tax work. The team also represents clients in tax litigation, with experience in transfer pricing cases, and tax-related criminal litigation and investigations. Dariusz Wasylkowski and Michał Nowacki are the department co-heads.
Goldman Sachs International
- Advised Investindustrial on the tax aspects of its takeover of HTL-Strefa.
- Assisted a French investor with the tax aspects of its acquisition of five commercial properties in Poland.
- Advising a multinational on all issues related to a new withholding tax system in Poland, relating to the payment of dividends abroad.
DLA Piper fields a strong team of lawyers and tax advisers, which handles a wide variety of standalone tax work, primarily focused on transactions and restructuring matters. It is also well-versed in warranty and indemnity insurance issues. Corporate tax expert Bartosz Matusik heads up the team, which includes 'reliable and knowledgeable' counsel Paweł Chodziński.
‘Experienced and with exceptional knowledge in tax matters, very competent and skilled negotiators.‘
‘The team is always very open and helpful. They are client and solution-oriented and provide advice that covers all aspects of a business.‘
‘Paweł Chodziński is a seasoned advocate and tax adviser. He possess all great qualities which make him stand out as unique among other advisers. He is always helpful and responsive to all our questions and concerns.‘
CORESTATE Capital Group
EDP Renewables Europe
Generali Europe Investments Holding
HCC Global Financial Products
Hewlett-Packard (HP Inc. Poland)
VINCI and its Polish subsidiaries
- Advising Metro Properties on the tax implications of selling an asset owned by Sezam FIZAN.
- Advising Corestate Capital Holding on the tax aspects of its acquisition of land in Gdańsk for the purpose of a student housing investment.
- Advising Newell on its reorganisation.
DWF Poland Jamka Sp.k's team, which transferred from K&L Gates' former Warsaw operations, is integrated into the firm's European tax practice, which provides clients with on-going tax advisory services, assists with transactional tax matters and handles international and local tax planning and restructuring work; the practice also acts in tax litigation and administrative enforcement proceedings, and is able to assist multinationals with transfer pricing issues. Adrian Jonca leads the department, and has significant experience in VAT disputes. Senior associate Katarzyna Stec is another key name with experience in corporate and personal income tax, real estate tax, VAT and transfer tax mandates.
Administrator of Alpine Bau GmbH
Polish Wind Energy Association
- Advised TFI PZU on a number of domestic and cross-border M&As.
- Representing C&A Polska in a tax refund case before the EU courts.
FKA Furtek Komosa Aleksandrowicz
Mariusz Aleksandrowicz leads the team at FKA Furtek Komosa Aleksandrowicz, which specialises in tax litigation and complex tax advisory work. The group is also noted for handling proceedings regarding tax evasion charges, anti-tax avoidance regulations and VAT missing trader fraud. Clients include a range of Polish companies, foreign investors, banks and financial institutions, in addition to a number of state-controlled companies.
Bank Ochrony Środowiska
Bank Gospodarstwa Krajowego
Polish Leasing Association
Zakłady Magnezytowe Ropczyce
BNP Paribas Bank
- Day-to-day tax advice to Bank Ochrony Środowiska.
- Advised Balcke-Dürr Polska on various tax and corporate matters and commercial agreements related to its activity in Poland.
- Ongoing legal and tax advice regarding the business and legal operations of the Polish Leasing Association.
GESSEL Attorneys at Law
GESSEL Attorneys at Law handles contentious and non-contentious tax matters for a variety of Polish individuals, corporates and multinational companies. The advisory and transactional practice assists clients with structuring equity transactions, issues related to personal and corporate income tax, and the full spectrum of indirect tax matters. In terms of litigation, department leader Janusz Fiszer has experience in proceedings before the administrative courts and Polish authorities.
‘Janusz Fiszer is an outstanding tax lawyer. He writes the best written opinions in Poland. Absolutely fantastic.‘
- Providing a major private television group with Polish tax advice and coordinating work with foreign tax advisers.
Gide Loyrette Nouel's group has a particularly busy advisory practice, assisting corporates with the tax aspects of a range of transactions, including M&A, corporate restructurings, real estate deals, industrial property rights and financing schemes. Corporate lawyer Dariusz Tokarczuk co-ordinates the team, which consists of international tax expert Ewa Żbikowska, transactional tax specialist Maciej Grela and Kamil Grzywka, who has experience in tax structuring matters.
Kapsch Telematic Services
KGHM Polska Miedź
ETI European Food Industries
B&B Hotels Polska
- Advised KGHM Polska Miedź on tax matters concerning the financing of a Chilean company.
- Advised Pointpark Group companies on securing intra-group payments against negative tax consequences resulting from the new withholding tax regime.
- Advised Société Générale on the tax aspects of the extension of a multinational factoring scheme.
Greenberg Traurig Grzesiak sp. k.'s team works with the firm's real estate, M&A and capital markets departments, providing notable transactional tax expertise. It is also instructed on standalone work, including tax planning matters, in addition to a variety of tax controversy and litigation issues. Experienced tax lawyer Marek Kozaczuk takes the lead.
BNP Paribas Group
KGAL Investment Management
PGE Energia Odnawialna
CVC Capital Partners
Tritax EuroBox plc
- Advised BNP Paribas Group on the tax aspects of its acquisition of the core banking business of Raiffeisen Bank Polska and the investment by EBRD in Bank BGŻ BNP Paribas.
- Advised PGE Energa Odnawialna on the taxation of wind farm real estate property and the investment in offshore wind energy farms located on the Baltic Sea within Poland’s borders.
- Advised Société Générale on the tax implications of its sale of Euro Bank to Bank Millennium.
Kancelaria Ozóg Tomczykowski Sp. z o.o.
Kancelaria Ożóg Tomczykowski Sp. z o.o. stands out for its comprehensive tax advisory practice, led by Paweł Tomczykowski and Anna Turska. Areas of expertise include succession issues, the development and implementation of private foundations, tax structurings, tax planning work (domestically and internationally), as well as transactional tax issues relating to M&A. Tax audits are another area where the firm has significant experience.
JW Construction Holding
- Providing tax advisory services to Konsalnet for a group restructuring and throughout the sale process of the business.
Newly promoted partner Agata Dziwisz heads up the department at Kochanski & Partners, which is noted for its expertise in tax planning and structuring work and international tax issues. Other areas the firm handles are transfer pricing work, customs issues, compliance mandates, as well as tax litigation before the Polish courts and authorities.
Echo Polska Properties
State Street Bank
Johnson Matthey plc
Credit Information Bureau
- Representing Forza Foods in a tax dispute before the Supreme Administrative Court, and in a complex tax compliance matter.
- Advising Johnson Matthey on tax related matters during two greenfield investments in Poland worth several billion Euros.
- Providing tax law advice to the Credit Information Bureau on the reorganisation and restructuring process of the capital group companies, with a particular emphasis on transfer pricing issues and the implementation of R&D tax relief.
'Particularly effective' counsel Mikołaj Bieniasz leads the tax department at Linklaters, which stands out for its transactional tax practice. Typical mandates include advising on the tax aspects of M&A, cross-border and domestic restructurings and real estate deals. The group also handles tax planning work, transfer pricing issues and matters related to financings.
‘The tax practice has extensive experience in cross-border instructions and remains a natural choice for high-quality tax advisory work on real estate transactions and M&A deals.‘
‘What makes the team truly unique is its multi-disciplinary and multi-jurisdictional approach and a harmonious relationship with both the other practices in Warsaw and the tax teams in its other offices.‘
‘Mikołaj Bieniasz has a thorough understanding of the business and a remarkable ability to communicate highly complex tax issues. He is an excellent project manager, with exceptional attention to detail.‘
Pojazdy Szynowe PESA Bydgoszcz
Patron Capital Advisers
Globalworth Poland Real Estate
Nuveen Real Estate
- Advised Pojazdy Szynowe PESA Bydgoszcz on the various tax implications of the restructuring of its existing financing and divestment to the Polish Development Fund.
- Advised NIAM on various tax implications of the acquisition of an office portfolio from Skanska, consisting of the Green2Day office building in Wrocław, Nowa Fabryczna office building in Łódź, and the first two buildings of the High5ive complex in Kraków.
- Advised Panattoni Europe on the construction of a production plant and research and development centre for Varroc, a manufacturer of innovative lighting and electronic systems for the automotive sector.
NGL Wiater sp.k.
NGL Wiater sp.k.'s tax practice expanded with the arrival of Bartosz Sankiewicz from Deloitte Doradztwo Podatkowe Dąbrowski i Wspólnicy Sp.k. in 2018. Since then, it fields a strong tax practice, which assists clients with matters involving Poland's tax administration. It also has extensive experience in handling fair market value cases for real estate companies involved in the renewable energy sector. Other areas of advisory expertise include corporate, individual and international taxation, and indirect tax mandates. On the transactional side, the group is knowledgeable in M&A-related tax and transfer pricing issues.
The group at Penteris fields a wide ranging tax practice, which advises on day-to-day issues in relation to Polish investments, transfer pricing matters, international tax planning work and tax effective structures, often for cross-border projects. The group is led by Tomasz Rysiak.
RIDA Development Corporation
Chicago-Poland Investment Group
- Advised Chicago-Poland Investment Group on the tax aspects of the sale of a 100% stake in Poland-based brewery Browar Namysłów to Polish beer group Grupa Żywiec.
- Advised Vastint Poland on the tax aspects of the sale of three office buildings, as a part of Business Garden Wrocław, to ISOC Group.
- Advised a retail company on the tax aspects of the restructuring and reorganisation of its operations in Poland.
Rymarz Zdort handles standalone tax matters, including litigation and controversy issues, and tax planning mandates. The group, which is co-led by Robert Krasnodebski and Leszek Tokarski, also regularly supports the firm's transactional work.
SSW Pragmatic Solutions
SSW Pragmatic Solutions' team is comprised of tax advisers, lawyers and economists, and is jointly led by Patrycja Goździowska and Tomasz Wickel, both of whom have strong tax advisory practices, and experience in handling M&A transactions, tax-efficient structures and equity deals.
‘Open, aggressive and business oriented.‘
‘They have a hands on approach and are solution-driven.‘
Marie Brizard Wine and Spirits
- Advised BoomBit Group on the tax aspects of its pre-IPO restructuring, a cross-border matter involving Poland, UK, US and Andorra.
- Advised Santander Bank Polska and its subsidiary Santander Towarzystwo Funduszy Inwestycyjnych on the tax aspects of the sale of its transfer agent division to ProService.
- Advised 7R on the tax aspects of its warehouse development project.
ZIMNY Doradcy Podatkowi
Tax boutique ZIMNY Doradcy Podatkowi handles tax advisory work and tax litigation for clients across the pharmaceuticals, financial, insurance, energy and investment fund sectors. Founding partner Marcin Zimny is an expert in non-contentious tax, and has a particular specialism in excise duty issues.
Philip Morris Polska Distribution
Motorent – Hertz
Groupe Sterne SAS
- Advising Phytopharm Klęka on various matters relating to excise duty.
- Conducting a tax due diligence of a target company in Poland for Groupe Sterne.
- Represented CGR Polska before the Polish Supreme Administrative Court in a VAT matter.