Ongoing consultations, opinions on transactions, support for accounting and contact with a person who knows the company's structure. This model works well with recurring questions and in capital groups.
TAX ADVISORY
Tax advisory
A company's tax settlements today amount to far more than an accounting issue. Their correctness requires taking into account a number of interrelated areas – from transactions with related entities and the structure of the capital group, through cross-border payments, to reporting obligations whose scope and significance have increased considerably in recent years.
We advise companies, capital groups and business owners on ongoing settlements, transactions and disputes with tax authorities. We combine the competences of tax advisers, attorneys-at-law, advocates and statutory auditors, which enables us to assess tax consequences together with their legal and financial implications.
The first conversation is free of charge and confidential. We respond within one business day.
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Tax advisers and attorneys-at-law
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70+ specialists
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Tax · Law · Audit · Accounting
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Warsaw · Katowice · Bydgoszcz
On this page
STARTING POINT
What is your matter about?
Tax advisory covers various situations and various modes of cooperation. Indicate what is closest to yours, and we will suggest where to start.
SCOPE OF SUPPORT
Scope of tax advisory services
Each of the following areas has a separate page with a description of the cooperation and the team.
Transfer pricing
We provide comprehensive transfer pricing advisory services, covering the development and implementation of transfer pricing policies, the analysis of transactions between related entities and the verification of their compliance with the arm's length principle.
We support entrepreneurs in identifying and mitigating tax risks, planning intra-group settlements and defending the methods and terms of transactions applied during audits and tax proceedings.
View serviceTransfer pricing documentation
We prepare comprehensive transfer pricing documentation, including local documentation (Local File), group documentation (Master File), benchmarking analyses and compliance analyses.
We support clients in identifying documentation obligations, verifying available exemptions and preparing and filing TPR information. We ensure timely fulfilment of reporting obligations, taking care of the consistency of the documentation with the actual course of transactions and the financial data of the enterprise.
Withholding tax (WHT)
We provide comprehensive advisory services on withholding tax on cross-border payments, in particular dividends, interest, royalties and remuneration for specific services.
We analyse the possibility of applying exemptions and preferential rates arising from domestic regulations and double taxation avoidance agreements. We support withholding agents in exercising due diligence, verifying the beneficial owner of receivables and applying the pay and refund mechanism.
View serviceAudits and tax proceedings
We represent taxpayers during verification proceedings, tax audits, customs and fiscal audits and tax proceedings.
We provide comprehensive legal services at every stage of a dispute with tax authorities, from responding to initial summonses, through preparing explanations, evidentiary motions and appeals against decisions, to representation before voivodeship administrative courts and the Supreme Administrative Court.
We develop a procedural strategy tailored to the specifics of each case.
Criminal fiscal proceedings (KKS)
We provide legal assistance in matters concerning fiscal penal liability, in particular of management board members, financial directors, chief accountants and other persons responsible for the tax settlements of enterprises.
We represent clients during activities conducted by law enforcement authorities and in court proceedings. We develop defence strategies, analyse the premises of fiscal penal liability and support clients in mitigating the risk of personal liability.
Tax planning and restructurings
We advise on tax planning and the reorganisation of business activity, taking into account business objectives and the applicable tax law.
We analyse the tax consequences of transformations, mergers and divisions of companies, contributions in kind, share exchanges and changes in the ownership structure. We support entrepreneurs in selecting tax-efficient solutions, identifying potential risks and preparing and carrying out restructuring processes, both domestic and cross-border.
Tax audit and review
We carry out comprehensive tax audits and reviews aimed at identifying irregularities and potential risks in the enterprise's settlements.
We verify the correctness of the application of tax regulations, analyse documentation and assess the internal procedures in place. We present recommendations concerning the elimination of identified irregularities, the possibility of making corrections and the implementation of solutions that mitigate tax risk and prepare the enterprise for a possible audit.
Tax due diligence
We carry out tax due diligence of enterprises and their assets in connection with planned capital and investment transactions.
We support both buyers and sellers by identifying tax risks that may affect the value of the transaction and the liability of its participants. We analyse historical tax settlements, liabilities and potential arrears as well as ongoing proceedings.
We prepare reports containing an assessment of the identified risks and recommendations concerning the protection of the client's interests.
CIT advisory
We provide comprehensive advisory services on corporate income tax, covering current tax settlements and the analysis of the effects of planned business transactions.
We support entrepreneurs in the correct recognition of taxable revenues and tax-deductible costs, the settlement of debt financing costs and the use of tax reliefs and preferences. We also advise on the selection and application of the lump-sum tax on company income (Estonian CIT), taking into account the specifics of the business activity conducted.
VAT advisory
We provide comprehensive advisory services on value added tax, covering domestic and international transactions.
We analyse the correctness of the VAT rates applied, the rules for determining the place of taxation, the moment when the tax obligation arises and the right to deduct input tax.
We support entrepreneurs in the settlement of intra-Community supplies and acquisitions of goods, exports, imports and chain transactions. We also assist in proceedings concerning VAT refunds and in the implementation of tax procedures.
PIT advisory
We provide advisory services on personal income tax, covering the current tax settlements of entrepreneurs, company partners and persons earning income from various sources.
We analyse the available forms of taxation of a sole proprietorship, taking into account the nature of the activity, the structure of revenues and costs and the possibility of using tax reliefs.
We support clients in preparing tax returns, settling foreign income and tax planning.
MDR and tax schemes
We provide comprehensive support in the identification and reporting of tax schemes (MDR).
We analyse transactions, arrangements and planned business activities for the presence of distinguishing features and information obligations arising from the provisions of the Tax Ordinance.
We support clients in preparing and submitting MDR information and in developing and implementing internal MDR procedures. We also advise on the obligations and liabilities of entities participating in arrangements.
Permanent establishment (PE / FE)
We advise on international tax law, with particular emphasis on the risk of creating a foreign permanent establishment (PE) for income tax purposes and a fixed establishment (FE) for VAT purposes.
We analyse cross-border business models in the light of domestic legislation, double taxation avoidance agreements and EU regulations.
We support entrepreneurs in identifying registration obligations, attributing income to the permanent establishment and correctly settling taxes in individual jurisdictions.
CURRENT OBLIGATIONS
Obligations that changed in the most recent settlements
Four changes that in 2026 affect most companies and require preparing or modifying internal processes, not just returns.
National e-Invoicing System
From 1 February 2026, invoices in KSeF are issued by companies that in 2024 exceeded 200 million PLN in sales, and from 1 April 2026 by the remaining entrepreneurs.
Receiving invoices through KSeF has become mandatory for everyone as of February. The smallest entities, issuing invoices up to 450 PLN and up to 10 thousand PLN per month, join the system from 1 January 2027.
A protective period applies throughout 2026: penalties for errors and for systems not being adapted are suspended. This is a time to put the document flow in order, not to postpone the matter.
JPK_CIT
The first reporting fell at the end of March 2026 for the year 2025. It covered tax capital groups irrespective of size and other CIT taxpayers whose turnover for 2025 exceeded 50 million euro.
The obligation requires reconciling accounting books with the tax settlement at the level of data, not summaries.
Top-up taxation (Pillar II)
Groups with consolidated revenues from 750 million euro are subject to a check whether the effective tax rate in a given jurisdiction reaches 15 per cent. If not, the obligation to pay the so-called top-up tax arises.
Since this regime is based largely on accounting data with numerous adjustments, the first step is to establish whether the group exceeds the threshold at all.
Minimum corporate income tax (CIT)
It applies to companies that incurred a loss from operating activities or whose operating profitability does not exceed 2 per cent.
The rate is 10 per cent of the base determined under the provisions of the CIT Act, and the Act also provides for a simplified method of calculating it. The amount of the minimum tax is reduced by the tax calculated under the general rules.
Legal status as at 23 September 2026.
WHEN IT IS WORTH IT
When companies turn to a tax adviser
Most often in one of the following situations. Each requires a different approach, has a different time horizon and entails different consequences in the event of inaction on the part of the company. The consequences may affect the company directly, but also members of its management bodies.
- 01The company enters into transactions with related parties and exceeds the documentation thresholds.
- 02The company pays dividends, interest, royalties or remuneration for intangible services abroad.
- 03A sale of shares, transformation, merger or division of the company is planned.
- 04A notification of a tax audit or customs and fiscal audit has been received.
- 05The tax authority has challenged the settlements and issued a decision determining the amount of arrears.
- 06The group is entering new markets or changing its intra-group settlement model.
- 07The company is implementing new reporting obligations and needs to determine their scope.
- 08The management board wants to limit its own liability for the company's settlements.
The earlier the tax consequences are established, the more solutions remain. Once a contract is signed or an audit is initiated, the catalogue of possible actions is already narrower.
MODEL OF COOPERATION
What cooperation looks like
We match the way we work to the specifics of the case, not the other way round. In practice, we rely on three models of cooperation.
Ongoing tax support
Current consultations, opinions on transactions and support for the tax department on an agreed monthly basis. A dedicated team knows the specifics and structure of the company, so it can respond efficiently to emerging issues without having to familiarise itself with the circumstances of the case and the business each time.
A project with a defined scope
Transfer pricing documentation, a review of settlements, due diligence, an opinion on a planned transaction or an application for an individual interpretation.
A clearly defined scope of work, timetable and remuneration.
Representation in a dispute
Audit, tax proceedings, appeal, complaint to the voivodeship administrative court and cassation appeal.
We provide comprehensive conduct of the case from the first summons through to a final ruling.
WHY RUSSELL BEDFORD
Why Russell Bedford
Taxes considered together with law and finance
The tax consequences of a transaction depend on its legal structure and on the accounting data. We work in teams combining tax advisers, attorneys-at-law, advocates and statutory auditors.
Advice and defence of the adopted solutions
We also handle cases where the tax authorities challenge the correctness of settlements.
In such cases, we prepare the documentation taking into account the perspective of a possible dispute, so that from the outset it addresses potential allegations and supports the company's position.
Advice for international groups
We advise entities operating in complex capital structures, including international groups.
We take into account both local legislation and settlements in Poland, as well as the tax policy, standards and reporting rules applicable at group level.
Part of an international network
Russell Bedford Poland belongs to the international group of specialists Russell Bedford International, which allows us to handle cases with a cross-border element in cooperation with advisers from other jurisdictions.
TEAM
The team leading tax projects
Oliwia Kasińska
Attorney-at-law | Tax adviser | Partner, Russell Bedford Tax Department
Oliwia Kasińska is an attorney-at-law, tax adviser and partner in the Russell Bedford Tax Department. She has over 10 years of professional experience in the area of tax law, with particular emphasis on value added tax (VAT), tax audits and proceedings conducted by tax authorities.
At Russell Bedford, we support corporate clients both in ongoing tax matters and in cases requiring contact with and representation before tax authorities and administrative courts.
Specialisations
- Value added tax (VAT)
- Tax audits
- Tax proceedings
- Tax disputes
- Representation before tax authorities
- Proceedings before administrative courts
Sebastian Golański
Advocate | Partner, Tax Department, Russell Bedford Poland
Sebastian Golański is an advocate and a partner in the Tax Department of Russell Bedford Poland. He has 11 years of experience in tax advisory – he advises international capital groups, corporate entities and individuals.
He specialises in tax planning, restructurings, M&A transactions and tax due diligence. He also supports clients in the area of tax audits and tax proceedings.
Specialisations
- Corporate income tax (CIT)
- Personal income tax (PIT)
- Tax planning
- Ownership and capital restructurings
- Mergers and acquisitions (M&A)
- Tax due diligence
- Audits and tax proceedings
- Family foundations
PROJECTS
Selected tax projects
Due to confidentiality, we present projects without indicating client names.
Manufacturing industry
Transfer pricing documentation for a capital group
Preparation of local and group documentation together with benchmarking analyses for companies in the Polish part of the group. The scope covered agreeing the intra-group settlement policy and preparing TPR information.
Defence industry
Tax due diligence for a foreign transaction
Conducting tax due diligence of a company for the purposes of a planned foreign transaction. The scope covered an analysis of key tax areas, identification of potential risks and arrears, and an assessment of their impact on the transaction.
The results of the analysis provided the basis for assessing the tax exposure and for further transaction decisions.
Retail and e-commerce
Review of settlements before an audit
Verification of the company's VAT and CIT settlements in connection with an expected audit. The analysis covered the identification of potential irregularities and areas of increased risk, as well as an assessment of the completeness of documentation.
The outcome of the work was a risk map together with recommendations for corrective actions that the company could implement before the audit began.
Logistics services
Representation in tax proceedings with a cross-border element
Representation of a company in tax proceedings concerning settlements with a related entity seated in Cyprus.
The scope of work covered an analysis of the flows between the companies, the correctness of the settlement of foreign payments and the economic and commercial justification of the adopted structure.
The case also included a successful challenge to the premises for applying the general anti-avoidance rule (GAAR).
Retail and e-commerce
Preparation of the transfer of a holding structure
Tax and legal planning of a holding structure in another country together with the transfer of assets and preparation of a complete analysis covering the tax consequences of the planned venture.
The recommendations covered corporate income tax, a GAAR analysis, the risk of a controlled foreign company (CFC) and personal income tax for shareholders and members of management bodies.
Finance / brokerage services
Representation in a customs and fiscal audit
Representation of a company in a customs and fiscal audit concerning the correctness of withholding tax (WHT) settlements and the acquisition of intangible services from a related entity.
The scope of work covered an analysis of possible strategies, an assessment of the risks associated with individual options, and the development and adoption of an appropriate procedural strategy during the audit.
Result
70%As a result of the actions taken, the amount of the assessed tax arrears was reduced by 70%.
Automotive industry
Tax analysis of cross-border transactions
Advisory on the tax consequences of cross-border transactions carried out by a company in the automotive industry.
The scope of work covered an analysis of goods and financial flows, the correctness of VAT settlements and the documentation obligations related to intra-group transactions.
Medical industry
Tax advisory on a group reorganisation
Tax advisory on the reorganisation of the structure of entities operating in the medical industry.
The scope of work covered an analysis of the tax consequences of the planned changes, identification of potential risks and development of a recommended model for carrying out the reorganisation, taking into account the consequences in the area of CIT, VAT and transfer pricing.
FAQ
Frequently asked questions about tax advisory
An accountant keeps the books and prepares settlements on the basis of documents. A tax adviser deals with assessing tax consequences and representing the taxpayer before tax authorities.
It is a profession of public trust: it is practised exclusively by persons entered on the list of tax advisers, covered by the obligation to maintain professional secrecy and by civil liability insurance.
OTHER AREAS
Other areas of support
Legal advisory
Business succession, company reorganisations, transactions and commercial disputes.
View serviceRestructuring and insolvency
Support for companies at risk of insolvency and their creditors.
View serviceAudit
Audits of financial statements and assurance services.
CONTACT
The sooner we learn about your matter, the more we can do.
Describe the company's situation: the type of transaction, the obligation to be fulfilled or the stage of proceedings. We will select a team and indicate possible next steps.
+48 22 276 61 80office@russellbedford.plThe information on this page is of a general nature and does not constitute tax or legal advice. An assessment of a situation requires an individual analysis.
Legal status as at 23 September 2026.