Tax advisory

International tax advisory services are designed for entrepreneurs whose business vision extends beyond one country. In an era of globalization, the digital economy and ever closer cooperation between national tax administrations, properly structuring cross-border operations is essential to maintain profitability and avoid tax risks. Every international operation—from providing services and posting employees to building holding structures—requires an analysis of domestic legislation and, above all, double taxation treaties (DTTs), EU directives and other relevant rules.

From the outset of expansion planning, it is crucial to determine tax residence accurately and identify the risk of creating a permanent establishment abroad. Unlike domestic tax advisory, international taxation requires knowledge of OECD rules and mandatory disclosure rules for cross-border arrangements (MDR). We design secure structures and capital flow models that take account of withholding tax on dividends, interest and royalties. We pay particular attention to transfer pricing and mechanisms designed to protect against the taxation of income earned by controlled foreign companies (CFCs). Related-party transactions must be recorded transparently to demonstrate that they are conducted at arm's length and that foreign entities have business substance.

We help coordinate tax processes across several countries, ensuring that the strategies adopted are consistent with current guidance on Base Erosion and Profit Shifting (BEPS). Our role is not limited to theoretical analysis: we implement foreign structures and ensure that their tax treatment is secure from the perspective of Polish tax authorities.

BTTP also supports foreign entities starting operations in Poland. We carry out the necessary tax, legal and accounting analyses and provide implementation and technical support for planned investments. We analyse the business purpose, the most suitable ways of operating and international settlement arrangements. Our knowledge of international tax law, combined with practical legal and tax experience, enables us to guide clients safely through cross-border restructuring processes. We design each structure to minimize tax risks and maximize the organization's capital efficiency.