Our tax team is managed by Gabriela Kazuch a tax advisor with many years of experience – also in tax authorities and fiscal control authorities. As an inspector of fiscal control, Gabriela verified transformations of business entities many times. Currently, as a tax advisor, she supports restructuring processes.

MKZ Partners Law Office has extensive experience in the scope of on-going tax and process services for Polish and foreign companies, in particular from the following industries: construction, development, production, advertising, commercial, energy, fuel and real estate. In the broadly defined area of taxation, we also support organizational units of local self-government.

Our advisers know perfectly well how the tax administration functions – both at the level of local offices and control authorities. We know how to use the above-mentioned knowledge and experience in representing the Client before tax authorities and administrative courts.

Our Law Office also offers broadly understood services in the scope of transfer pricing and supports Clients in fulfilling their reporting obligations under MDR.

We also support our Clients in the area of income tax (PIT, CIT), VAT tax, civil law transactions tax, tax and court proceedings (at each stage of these proceedings), property taxes, tax planning and international taxation.

In our legal practice, we focus in particular on the following aspects of tax law:

Tax audits as well as customs and tax controls

Our Law Office effectively represents our Clients in tax audits carried out by tax offices as well as in customs and tax audits carried out by Customs and Tax Offices.

We help and represent Clients at every stage of the audit, especially at their early stage, which undoubtedly matters to the proper collection of evidence and its assessment by tax administration authorities. This allows us to effectively defend our Client against decisions of the authorities. Taking care of the interests of our Clients, we also try to quickly complete the audit or checking activities. We represent our Clients at every stage of the proceedings; we prepare responses to reservations, appeals against decisions, complaints, appeal against the sentence, and responses to complaints and represent Clients before administrative courts.

Proceedings

Our Law Firm effectively represents Clients in tax proceedings, carried out at every stage. We conduct tax proceedings initiated against natural persons, natural persons conducting sole proprietorship and legal persons. We deal with proceedings regarding tax liabilities and ruling on the liability of third parties. Members of our tax team are also people who gained their experience working on managerial positions in tax authorities: Tax Offices, Tax Inspection Offices, Customs and Tax Offices, both in the departments responsible for inspections and judicial decisions. We have experience in the scope of procedural and substantive issues regarding the conduct of appeal proceedings, or procedures for the initiation of “extraordinary procedures” – resumption or annulment. Knowing perfectly how the tax administration functions – both at the level of the local tax office and inspection authorities – we are able to effectively use this knowledge and experience in representing the Client before tax authorities and administrative courts.

We will provide you with support in particular in such aspects as:

participation in the hearing of the party and witnesses,

assistance in obtaining a tax refund and help in recovering overpaid tax,

representation during tax, customs and tax inspection or inspection activities,

preparation of responses to the appeals of the authorities,

verification and comment on the evidence collected by the authority,

preparation of reservations to tax control protocols,

preparation of an assessment of the legitimacy of the correction,

preparation of complaints,

preparation of appeals,

preparation of a complaint to the Regional Administrative Court, preparation of an appeal against the sentence to the Supreme Administrative Court.

At each stage of the proceedings, we provide assistance in the scope of verification of documents provided by the Client to the office, we will review and evaluate the evidence collected by the authority during the proceedings and assess the legitimacy of the dispute, we will also identify the risk areas and assess the costs of the proceedings.

Opinions, memoranda, analyses

On our Client’s request we will prepare opinions and memoranda regarding all types of projects, contracts or other tax related issues regarding the current operations of our Client. The combination of legal and tax specialists in one team allows us to quickly identify potential tax risks at an early stage of the project.

Due Diligence – tax audits, reports

We will prepare tax audits for you. Depending on the project, they may concern both entire enterprises and individual assets. Depending on the order, we will clearly define the legal and tax status of the asset or the entire enterprise. Our advisers have extensive experience in the preparation of analyses preceding transactions related to the company or its assets. Depending on the needs, we secure both sides of the transaction by drawing up joint applications for an interpretation of individual tax law. We provide help/support at every stage of the transaction.

Applications for tax law interpretations – tax risk management

Aiming at minimizing tax risk, we provide our Clients with the widest range of protection possible by obtaining favourable (positive) interpretations of tax law. Individual interpretations of tax law provisions are in many cases an instrument for the taxpayer, who can significantly reduce the tax risk of actions taken. This applies in particular to situations where the tax interpretation has been delivered to the taxpayer before taking action with which the interpretation is related to. However, the application for issuing interpretations of tax law is of key importance. Only a correctly formulated application will allow the taxpayer to take advantage of all the effects of the individual interpretation received.

Income taxes (PIT, CIT)

We offer our Clients comprehensive advice on income taxes. We provide support in both current problems related to conducted business and provide support in the recovery of improperly collected tax (applications for overpayment). We represent our Clients at every stage of inspection and tax proceedings. As part of tax reviews, we evaluate the accounting principles adopted in the company and their correctness.

VAT

We provide ongoing tax and legal advice as well as full service of transactions in the scope of tax on goods and services, including sale/acquisition of real estate, in particular in matters related to tax assessment, VAT exemption, real estate disputes and adequate safety of real estate transactions.