Month: June 2025

At the beginning of this year, the tax advisors from our firm conducted a CIT and VAT tax review for 2023 for a company operating in the employment agency services sector, generating significant revenues exceeding 20 million PLN.

The company has been active in the market for several years but had not previously commissioned a broader legal and tax analysis of its CIT and VAT settlements. It relied on outsourced accounting and payroll services, having full trust in the person responsible for its bookkeeping and tax settlements.

A casual tax inquiry prompted the CEO to approach our firm and ultimately entrust us with a full analysis of the company’s tax settlements for 2023.

We carried out a detailed examination of the company’s tax situation, verifying compliance with tax regulations for transactions and documents. During the audit, we identified deficiencies even in fundamental areas, such as:

• Delays in recognizing revenue and VAT obligations,
• Omitting some purchase invoices from the books,
• Incorrectly recording purchase invoices as sales,
• Failing to withhold and remit withholding tax for recruitment services provided by a foreign entity.

Our work was summarized in a concise report, enabling the CEO to:

• Gain broader tax insights “at a glance,”
• Identify not only tax underpayments but also overpayments, indicating potential areas for reducing tax liabilities,
• Make corrections to settlements prior to a tax audit, thereby avoiding substantial financial penalties under the Fiscal Penal Code,
• Decide to replace the accountant and transition to ongoing support from our tax advisors.

Tax audits and reviews are often associated with inspections, but it is worth recognizing their benefits. By entrusting your books, documents, and records to the advisors at our firm, you can leverage our expertise!

Let’s work together!

Our firm provides tax advisory services in the area of transfer pricing, preparing both local and group transfer pricing documentation in accordance with the requirements set out in the Corporate Income Tax Act, the Personal Income Tax Act, and applicable regulations. We also ensure proper reporting of transactions on TPR-C and TPR-P forms.

When preparing transfer pricing documentation, our team thoroughly analyzes transactions conducted by clients that require documentation and reporting to tax authorities—covering both transactions with related entities and those involving parties located in jurisdictions practicing harmful tax competition.

At the same time, we examine the prerequisites that may allow our clients to benefit from exemptions from documentation requirements or simplify the preparation process.

Particularly appealing to our clients is the application of provisions enabling the waiver of the obligation to prepare benchmarking and compliance analyses. Drawing on the provisions of tax laws and the Entrepreneurs’ Law, our experts assess clients’ financial and staffing data to determine whether they qualify as micro or small enterprises for a given tax year.

Thanks to these analyses, it has often been possible to simplify the structure of transfer pricing documentation, significantly reducing the required workload and preparation costs.

By cooperating with our firm, clients can:

• Eliminate potential risks associated with improper transfer pricing documentation,
• Gain confidence in the reported transactions and their values,
• Take advantage of regulatory simplifications, reducing costs and minimizing the involvement of their internal staff.

Tax advisory support in the area of transfer pricing is our specialty, and thanks to our extensive experience, we can deliver effective solutions.

Our client Wiktor operates a sole proprietorship and faces high income taxes and health insurance contributions. He approached our firm seeking analysis and recommendations for the most advantageous business structure that would allow for a significant reduction in budgetary burdens.

Our team conducted a thorough analysis of Wiktor’s financial data from the previous and current year, evaluating the nature of his business, development plans, and financial situation. We examined alternatives for transferring his sole proprietorship to various corporate structures (limited liability company, limited partnership, and joint-stock limited partnership), highlighting the tax implications of each scenario.

We prepared a detailed calculation of estimated tax burdens for each business form based on historical data and future projections.

We presented Wiktor with the advantages and disadvantages of each business structure, including a limited liability company under the Estonian CIT regime, a limited partnership, and a joint-stock limited partnership. Based on this assessment, we recommended the optimal scenario tailored to Wiktor’s business, taking into account both short-term and long-term tax benefits.

Client Benefits:

• Tax Optimization: The most advantageous solution for Wiktor’s company turned out to be the formation of a limited liability company and transitioning to the Estonian CIT system. Maintaining revenues at 15.7 million PLN, this change could result in annual savings of approximately 185,000 PLN in taxes and social security contributions.
• Long-Term Flexibility: In the event of significant business growth in the coming years (with revenues and expenses doubling), the most tax-efficient solutions would be a limited partnership or a joint-stock limited partnership, generating savings of around 340,000 PLN per year.
• Transparency: Wiktor received a detailed analysis clearly outlining the advantages and disadvantages of each business form and providing a comprehensive calculation of tax burdens.

Through a detailed financial and tax analysis, our firm helped Wiktor make an informed decision about changing his business structure. As a result, our client gained legal and financial security and can significantly reduce his tax burdens and health insurance contributions.

If you have any questions about tax optimization or other aspects of running a business, we encourage you to contact our firm.

In recent months, our Firm had the opportunity to assist an entrepreneur in the medical industry with selecting the appropriate flat-rate tax rate and securely structuring cooperation with his company.

The entrepreneur, running an individual medical practice, also served as the CEO of a company conducting clinical trials for pharmaceutical firms. In addition to providing basic medical services, such as dermatological consultations, our client also performed clinical trial services for his company, invoicing and receiving remuneration for these services.

Initially, the client taxed all his income at a flat-rate of 14%, as specified in the law for medical services. He turned to our Firm for advice on this matter.

After a thorough analysis of contracts, actual activities, and the latest tax authority interpretations, our experts proposed applying a lower flat-rate tax of 8.5% for clinical trial services. Implementing this change, based on two clinical trial projects per month worth a total of PLN 80,000, would allow the client to save nearly PLN 50,000 in income tax annually!

Moreover, during the review of the client’s contracts, our experts identified irregularities that could expose him to disputes with tax authorities during audits. Cooperation between partners and their companies is currently under increased scrutiny from tax authorities, requiring special attention when structuring these relationships.

We proposed alternative, secure solutions to help the client properly structure cooperation with the company and avoid disputes with the tax office.

By working with our experts, the client gained:

• Confirmation of the possibility to apply the lower flat-rate tax rate, in line with the latest interpretation of the Director of the National Tax Information (KIS), enabling a legal reduction in taxes by nearly 50%.
• A comprehensive analysis of the cooperation model with the company, highlighting potential risks.
• Proposals for implementing safer solutions to minimize the risk of disputes with tax authorities.
• Peace of mind, thanks to confidence in the accuracy of tax settlements.

If your company also needs a professional analysis of the appropriate flat-rate tax rate for recorded revenues or an evaluation of the cooperation and settlements model between partners and the company, our experts are ready to provide reliable support in this area.