Tax consultancy

The Polish Holding Company (PSH) regime is a tax solution introduced to increase Poland's attractiveness as a location for capital investment and the management of groups of companies. It is an alternative to foreign jurisdictions, designed for entrepreneurs seeking to effectively and safely consolidate their businesses at the domestic level. The primary goal of the PSH is to enable tax-neutral capital flow within the group, which directly translates into the ability to reinvest profits and build the value of the entire holding. From the moment this structure is implemented, compliance with a number of restrictive statutory requirements becomes crucial to the right to benefit from preferential tax treatment.

Unlike standard ownership structures, the PSH regime offers two fundamental benefits: full corporate income tax exemption for dividends received from subsidiaries and tax exemption for gains from the sale of shares in these companies. However, leveraging these preferences requires precisely structuring capital relationships and ensuring an appropriate level of business substance. Records of relationships and monitoring of shareholding periods must be rigorously maintained to ensure that the holding company can fully utilize its privileges upon transaction or distribution of profits.

At BTTP, we ensure that the holding company structure is transparent and fully resistant to scrutiny by tax authorities. Many aspects of the PSH's operation, including the definition of a subsidiary and the requirement to avoid other exemptions (e.g., within Special Economic Zones), raise practical questions of interpretation. BTTP offers comprehensive support in the process of transforming current structures into a holding company, combining strategic advice with operational oversight of corporate documentation.

We help clients verify the status of subsidiaries, prepare necessary declarations, and design corporate governance mechanisms that are consistent with tax requirements.

The synergy of tax, legal, and accounting expertise within our firm allows for the smooth implementation of the restructuring processes necessary to enter the PSH regime. A well-designed holding company offers not only tax benefits but, above all, a tool for secure succession and stable capital management. Therefore, we design every structure with the long-term security and growth of our clients' businesses in mind.