Tax consultancy

Changing tax residence is one of the most complex processes in international tax law, requiring knowledge of the intersection of Polish domestic law and double taxation treaties (DTTs). In the era of globalization and remote work, transferring one's center of vital interests has become a natural development step for many entrepreneurs and investors, although from a tax perspective, it can pose a risk of bilateral claims from tax authorities. At BTTP, we approach this process comprehensively, analyzing clients' situations primarily through the lens of their center of personal or economic interests.

BTTP's substantive support focuses primarily on minimizing the risk of a change of residence being deemed "sham." Tax authorities are increasingly examining a taxpayer's actual ties to the country, analyzing not only their place of residence but also the location of real estate, bank accounts, and even social activities or children's schooling. Our role includes preparing, among other things, a defense file—a collection of evidence confirming the permanent transfer of one's center of vital interests to the new jurisdiction. A crucial element of the change of residence process is advice on the tax on unrealized gains, also known as the Exit Tax. By combining the expertise of tax advisors and lawyers, we ensure a smooth transition through administrative processes, such as obtaining a certificate of residence in the new country and formally reporting the cessation of tax liability in Poland. BTTP's goal is to ensure complete tax security, ensuring that the change of residence is effective and resistant to potential tax audits in the future.