Tax consultancy

International tax advisory services are designed for entrepreneurs whose business vision extends beyond the borders of a single country. In the era of globalization, the digital economy, and increasingly close cooperation between tax administrations across different countries, properly structuring cross-border operations is essential for maintaining profitability and avoiding tax risks. Every international operation—from the provision of services, through the posting of employees, to the development of holding structures—requires analysis not only of domestic regulations but, above all, of double taxation treaties (DTTs) and EU directives, among others.

From the very beginning of expansion planning, it is crucial to precisely define tax residence and identify the risk of creating a permanent establishment. Unlike domestic tax advice, international taxation requires knowledge of OECD regulations and the regulations on reporting cross-border arrangements (MDR). Our support focuses on designing secure structures and capital flow models, taking into account withholding tax on dividends, interest, and royalties. We pay particular attention to transfer pricing and mechanisms protecting the income of controlled foreign companies (CFCs) from taxation. Related-party transactions must be transparently recorded to fully justify the arm's length nature of settlements and the business substance of foreign entities.

We assist in coordinating tax processes across multiple countries simultaneously, ensuring that adopted strategies are consistent with current Base Erosion Prevention (BEPS) guidelines. Our role extends beyond theoretical analysis; we also implement cross-border structures, ensuring the security of settlements from the perspective of Polish tax authorities.

BTTP also provides support for foreign entities launching operations in Poland. In this case, we conduct the necessary tax, legal, and accounting analyses, as well as provide implementation and technical support for planned investments. We analyze business objectives, the most optimal forms of conducting business, and international settlements. The synergy of our knowledge of international tax law and practical legal and tax experience allows us to safely guide clients through cross-border restructuring processes. We design each structure with the goal of minimizing fiscal risks and maximizing the organization's capital efficiency.