TPA Hrsp. z o.o.

Tax Litigation

Why? The Polish model of settling tax obligations by entrepreneurs, which involves self-calculation of taxes due in a lawful and properly documented manner, does not have to entail neither routine nor frequent inspections of tax authorities. Numerous entrepreneurs operate for months or even years without any inspection or proceedings initiated by the entrepreneur. However, the […]

Tax Procedures

Why? The ever-growing multitude, complexity and variability of tax regulations boosts the cost of administering tax operations at each enterprise, and also increases the risk of potential irregularities and disputes against tax authorities, often leading to fiscal, penal and fiscal, or even penal liability. Tax procedures as an instrument that constitutes a set of appropriately […]

Taxation of New Technologies

Why? The modern world is under continuous evolution powered by new technologies. Digital revolutions, artificial intelligence, blockchain or the Internet are just examples of innovations that have changed the economic, social and every other aspect of life forever. New technologies bring vast opportunities on one hand, but entail numerous challenges, including tax-related, on the other. […]

Transaction Advisory and Tax Due Diligence

What for? Audits bearing the ‘due diligence’ phrase are already standard in terms of due diligence within an investment process that involves purchasing shares in an existing business entity that is independent of the buyer. Purchasing shares in, e.g., a company, unlike purchasing only the assets in this company, entails an investor taking over its […]

Transfer Pricing

Why? The issue of transfer pricing concerns the obligation to preserve the market relevance (so-called arm’s length principle) of the terms and conditions integrated into transaction between affiliates (so-called controlled transactions). To be as straightforward as possible, the prices in such transactions should not deviate from the prices applicable in uncontrolled transactions, namely, between independent […]

Withholding Tax

Why? One of the most important modifications that was implemented recently in terms of withholding tax (WHT) regulations is the introduction of a so-called pay-and-refund mechanism. It involves the requirement to collect a tax if the total amount of receivables paid to the same taxpayer on account of interest, licensing fees or dividends exceeds PLN […]