We design tax structures that survive audits — and defend them when they happen. KSeF readiness, Polski Ład, IP Box, JPK_CIT, transfer pricing, KAS audits, WSA/NSA litigation, family foundation structuring. Eight family foundations structured since May 2023.
KSeF mandatory deadline: 1 April 2026 (B2B). Integration testing takes 3–6 weeks.
Send your situation in 5–10 sentences via form or call.
A partner — not a junior — reads it within 2 business hours.
We propose the scope, timeline, and fee — before any commitment.
Work begins only after you approve the engagement letter.
Most common cross-border matters in this practice arrive from:
We publish in-depth analyses weekly. The full archive is available in the Insights section →.
1 April 2026 for B2B taxpayers with sales above PLN 200m in 2024. 1 July 2026 for all other B2B taxpayers. B2C remains voluntary. Sanctions (fines on suppliers and recipients) start on 1 January 2027 — a 9-month grace period.
Yes — and this is one of its key features. A fundacja rodzinna can hold shares in operating sp. z o.o. and S.A. companies, real estate, and securities. Dividends and capital gains realised by the foundation are exempt from CIT until distributed to beneficiaries (then 15% PIT for category-1 relatives, 19% otherwise).
A standard tax audit (kontrola podatkowa) lasts up to 6 months for large entrepreneurs, 12 months for micro/small/medium. Complex audits with international elements can extend further. We respond to every kwestionariusz within the prescribed deadline — usually 7 days — and prepare witness testimony in advance of any oświadczenie.
Describe the situation briefly. A partner — not a junior associate — will respond within 2 business hours.