Restructuring and foreign settlements
In the course of our projects we provide Clients with solutions that allow them to increase their control and tax safety.
From the perspective of enterprises that do business within international structures or have dealings with foreign entities it is crucial to develop an appropriate international tax strategy, especially for investors that plan restructuring projects or want to transfer part of their business abroad in order to manage assets more effectively.
Building an international strategy requires experience and knowledge about the opportunities offered by foreign tax regimes and the changing regulations of double tax treaties. This insight is particularly important in view of the recent modifications of the Polish tax regulations, inter alia the introduction of controlled foreign corporation tax, new transfer pricing requirements and double tax avoidance clauses.
Hence, enterprises should set great store by the properly planned and implemented business model that can increase their potential for development, and they should also be aware of the double taxation risks involved.
How can we help?
We have many years of experience in strategic advice and business restructuring, especially in the sphere of development and implementation of solutions that increase the effectiveness of business activities and management of double taxation risks.
We offer our assistance in the planning of restructuring and we support clients in development of tax solutions that are specifically tailored to the needs of their businesses.
Our expertiese and services
Deloitte provides state-of-the-art comprehensive tax services for natural persons and corporations. In particular, our offer includes:
- support in the process of planning and implementing business restructuring in Poland, also with assistance of specialized vehicles operating abroad - in the Netherlands, Switzerland, Luxembourg and Malta;
- support in carrying out foreign investment projects and doing business abroad;
- advisory in reorganization of group cash flows to increase the efficiency of the company's operations within an international complex;
- analysis of the current structures to identify the risks arising from controlled foreign corporation and double tax avoidance rules;
- tax reviews and training in the scope of the Polish corporate income tax with a special focus on transactions carried out in international trading (among others, withholding tax on dividend, interest, licences, intragroup services, cash pooling and netting);
- assistance in the process of setting up capital groups and development of solutions that make it possible to consolidate group tax result;
- tax litigation concerning refunds of the withholding tax paid in Poland on dividend, interest, royalties and other dues resulting in double taxation;
- tax advisory on the activities conducted by foreign entrepreneurs in Poland and by Polish entrepreneurs abroad, including development of head office - branch tax settlement models;
- assistance in recognition in Poland of tax losses incurred by a foreign branch of a Polish enterprise;
- support in initiating mutual agreement procedures (MAP).