Corporate income tax is one of the most complex and dynamically evolving areas of Polish tax law. We offer comprehensive support — from day-to-day settlements to advanced restructuring and cross-border projects — combining an in-depth knowledge of regulations and their application by tax authorities and courts with a practical approach to business needs.
Businesses operating in Poland must continuously respond to legislative changes, both domestic and those arising from the implementation of EU directives, as well as the evolving practice of tax authorities and administrative courts. Key risk areas include: correct recognition of revenues and tax-deductible costs, limitations on deducting debt financing costs, cross-border settlements including withholding tax, transfer pricing, and tax risks in transactions involving the acquisition of companies or assets. Proper management of the CIT area is a prerequisite for the financial security and efficiency of every enterprise.
Who is it for?
Our services are addressed to CIT taxpayers — both residents and non-residents conducting business in Poland or earning income here:
- Domestic companies seeking accuracy and security in CIT settlements, including those opting for lump-sum taxation on company income (Estonian CIT)
- Capital groups considering the formation of a tax capital group or managing intra-group settlements and transfer pricing
- Companies planning restructurings: mergers, divisions, transformations, contributions of an enterprise or an organised part of an enterprise
- Companies planning investments and transactions of any type, as well as those dealing with new and complex contract structures
- Entities conducting cross-border activities, using double taxation treaties, settling withholding tax liabilities, or holding controlled foreign companies
- Companies using debt financing, leasing, or planning changes to their financing structure requiring analysis under thin capitalisation rules
- Investors carrying out investment projects requiring tax impact analysis, settlement of capital expenditures, and verification of available tax preferences (SEZ, PSI, R&D relief, IP Box)
- Companies requiring support during tax audits, customs and fiscal inspections, or tax proceedings before tax authorities and administrative courts
- Entities obliged to report tax schemes (MDR) and fulfil extended reporting obligations, including TPR, CIT/TP, and CBC-R
How we work
Day-to-Day CIT Advisory
- Consultations and tax opinions on the classification of revenues and costs
- Analysis of the tax implications of agreements and transactions
- Preparation of CIT-8 tax returns and annexes
- Applications for individual tax rulings
- Advisory on CIT advance payments and the choice of payment method
- Support in applying double taxation treaties (DTTs)
Tax Reviews
- Analysis of the methodology for transitioning from accounting to taxable profit (permanent and temporary differences)
- Verification of the accuracy of revenue and tax-deductible cost recognition
- Assessment of the correctness of deferred tax calculations
- Identification of tax risks and remedial recommendations
- Review for compliance with transfer pricing regulations
- Verification of MDR and CbCR reporting obligations
Financing and Investments
- Analysis of the tax efficiency of financing models
- Debt financing costs
- Settlement of capital expenditures and depreciation rules for fixed assets and intangible assets
- Tax preferences for investors: R&D relief, IP Box, SEZ/PSI
- Analysis of tax implications of capital investments (shares, stocks, financial instruments)
- Settlement of foreign exchange differences using the accounting or tax method
Restructurings and Reorganisations
- Analysis of tax implications of mergers, divisions, and transformations of companies
- Tax succession — rights and obligations of the legal successor
- Contributions of an enterprise and an organised part of an enterprise — tax neutrality and conditions for maintaining it
- Establishment and operation of tax capital groups (TCG)
- Risk analysis regarding the application of the GAAR clause and specific anti-avoidance provisions
- Relocation of assets and functions within capital groups — exit tax
Cross-Border Activities and WHT
- Application of DTTs: tax residency, permanent establishment (PE), allocation of taxing rights
- Withholding tax (WHT) — payer obligations, pay & refund procedure, certificates of residence
- Taxation of controlled foreign companies (CFC)
- Pillar Two Directive — analysis of obligations and calculation
- VAT registration and fixed establishment in the context of CIT
Disputes and Tax Proceedings
- Representation during tax audits and customs and fiscal inspections
- Preparation for audits: documentation, procedures, due diligence
- Appeals against decisions of first and second-instance tax authorities
- Complaints to Provincial Administrative Courts (WSA) and the Supreme Administrative Court (NSA)
- Applications for recognition of overpayment and tax refunds
- Advance pricing agreements for transfer pricing
