#3 FDI source (12.7%). SOPARFI and SCSp structures dominate fund and holding flows. Substance and Pillar 2 review essential.
#3 FDI source (12.7%). SOPARFI and SCSp structures dominate fund and holding flows. Substance and Pillar 2 review essential.
Netherlands, Luxembourg, Belgium and France are the dominant choices for holding-structure layering above a Polish operating company — historically through SOPARFI (LU), Dutch BV or French SAS structures.
Recurring issues: ATAD 3 substance requirements ("shell-entity" test), Pillar 2 Top-Up Tax exposure, DAC 6/7/8 reporting, withholding-tax analysis on intra-group dividends, and the EU FDI Screening Regulation's application to ultimate beneficial owners.
For matters connecting Poland and Luxembourg, we coordinate with trusted local partners — and where the matter falls within our priority partner jurisdictions, we engage lawyers from the partner office directly. The Polish-side partner remains the client's single point of contact throughout. Approach outline is provided within 48 hours of initial engagement.
Coordination with local partners. Counsel introductions in Luxembourg are made on a case-by-case basis. We do not maintain exclusive referral arrangements. The selection criterion is fit to the specific matter: regulatory expertise, sector knowledge, transaction size, and (for litigation) seat-court familiarity. Engagement letters always disclose any introducing-counsel fees.
Within two business hours during CET working hours, the Polish-side partner reads your message and decides whether the matter requires local Luxembourg counsel coordination, network deployment, or sole Polish handling. The first approach outline — scope, timeline, and fee proposal — is sent within 48 hours of initial engagement, with no commitment from your side.
No — and we say so transparently. KORDECKI & Partners is admitted to practise Polish law. For substantive Luxembourg legal questions we engage trusted local counsel, either through our partner network (for the seven network jurisdictions) or via curated partner-firm relationships maintained since 2009. The Polish partner remains your single point of contact and coordinates billing, scope and timeline.
The Poland–Luxembourg double-tax treaty is in force and shapes the analysis of withholding-tax, permanent establishment and transfer-pricing positions. Investment protection is covered by the intra-EU investor-protection framework. Where the matter involves EU directives (Parent-Subsidiary, Interest-and-Royalties, Anti-Tax-Avoidance), those override or supplement bilateral provisions. We map all three layers in the first written outline.
We coordinate with local partners in Luxembourg so you work with one team, not two. We outline the approach within 48 hours.