Our international tax practice advises on tax consequences of existing structures and transactions as well as tax planning scenarios involving foreign tax jurisdictions.
In our advisory services, we rely on our experience and knowledge ofthe tax regulations applicable in foreign jurisdictions, in order to take advantage of reliefs, exemptions or other specific solutions provided for under directives, double taxation treaties and domestic regulations in force in the given country. Our cooperation with reputable foreign tax and legal consulting firms allows us to offer advisory servicesrelated to design of structures for investing, doing business and financing of operations in particular countriesas well as exit scenarios. To ensure that our clients receive comprehensive services, we also collaborate with entitiesrendering support in the process of establishing capital companies and partnerships in territoriespresenting tax optimisation opportunities and providing legal, administrative, tax and accounting services to such vehicles.
In particular, we advise on:
- withholding tax implications arising in connection with payment of interest, dividends or licence fees;
- possibilities of taking advantage of exemptions, reliefs and deductions made available under EU directives and international agreements and the associated documentation requirements;
- solutions for financing of operations involving cash pooling or netting structures;
- verification of obligations resulting from controlled foreign company (CFC) regimes;
- existence of a permanent establishment of a foreign enterprise on the territory of Poland and we offer our support in documentation of settlements conducted between the head office and the permanent establishment as well as formulation of principles of allocation of head office revenues and costs to such a permanent establishment;
- taxation of foreign nationals staying in Poland and of Polish residents seconded to work abroad.