The tax authority can do more damage than a thief, because it acts in the name of the law. Tax advisory exists to check whether the authority actually kept to that law. Better still: to put your affairs in order before the tax office asks any questions.
Skarbiec Law Firm has provided tax advice since 2006. Our tax advisors work alongside litigators, so we look at every tax decision the way an official, an administrative court and, on occasion, a prosecutor will look at it a few years from now. We do not promise that taxes can be avoided. We promise that you will pay what you must, no more, and that you will know why.
Where are you starting from?
The tax office has opened an inspection >>> We represent you from the first letter, before your answers become part of the case file. >>> See how we can help: Tax inspections
I have received an unfavorable decision >>> We assess your chances, draft the appeal and run the case before the administrative court. >>> See how we can help: Tax disputes
I am planning a decision or a transaction >>> We check the tax consequences of a sale, a reorganization or a new structure before you sign anything. >>> See how we can help: Our services
I need ongoing support >>> An advisor who knows your business handles CIT, PIT, VAT, withholding tax and transfer pricing day to day. >>> See how we can help: Ongoing tax support
A tax is never just a tax
Poland’s tax system is complicated not because of bad design but because of no design at all. It has grown for decades by accretion: provision upon provision, exception upon exception, one interpretation overturning another. The same transaction can be classified in three different ways by three different officials. The consequences of a wrong classification always land on the same party: the taxpayer.
That is why we never answer a tax question in isolation. One decision has several dimensions, and any of them can decide the outcome:
- Tax. How much you pay, when, and with what risk of a later adjustment.
- Evidential. How the decision will look in an inspection file five years from now, and whether you will have anything to defend it with.
- Criminal. Where a mistake ends and a charge begins. We know that line from courtrooms, not only from the statute books (criminal defense in fiscal and economic matters).
- Ownership. Corporate structure, profit distribution, succession, exit from an investment.
- International. Withholding tax, transfer pricing, controlled foreign companies, automatic exchange of information. An international holding structure in Cyprus, Malta, Dubai or the United States can make sense, or turn out to be a trap if it has no real substance.
This is how a tax advisory firm works when tax advisors and litigators sit at one table. The line between optimization and indictment can be thin, so we look at it from both sides at once.
Institutional memory matters too. Some arrangements that were standard twenty years ago now qualify as aggressive tax planning. Some of what once looked risky has since been sanctioned by the courts. We have watched these shifts since 2006, and we know which way the authorities’ practice usually moves.
Ongoing tax advice and compliance
PIT, CIT, VAT: three acronyms that hide labyrinths of rules. Each tax has its own logic, its own traps and its own opportunities. Below is what we do day to day. Each service has its own page describing what it covers and how it runs.
Ongoing support means you do not have to track every change in the law yourself or gamble on unclear rules. You have an advisor who knows your situation, talks to your accountants and reacts before a problem becomes serious. We cover every tax a company and its owner come across:
Transfer pricing
dealings with related parties and the documentation behind them.
Minimum income tax
whether your company is within scope and how to check before you file.
Real estate tax:
classification of structures, disputes with municipalities, recovery of overpayments.
Personal taxes in Poland
The tax affairs of the owner and the family, such as private assets or foreign income.
Scope of our tax advisory services
Tax rulings
We prepare applications for individual tax rulings, which give formal protection against a change in the authority’s position, and we advise when to ask the authority and when it is wiser not to.
Tax opinions and analyses
Tax opinions and analyses show the consequences of a planned decision before you make it, and leave a record that you acted with due care.
Tax health check
A tax health check is an inspection you commission yourself, to find errors in your settlements while they can still be corrected without penalties.
Transaction review (GAAR)
We check whether a planned structure will withstand the general anti-avoidance option (GAAR), and where needed we apply to the Head of the National Revenue Administration for a protective tax ruling.
DAC7 reporting
We help operators of digital platforms implement the reporting obligations under the DAC7 directive and avoid an administrative fine of up to PLN 1 million as well as fiscal penal liability.
Tax advisor in Warsaw and online
Our office is in Warsaw, and this is where we meet clients who prefer a conversation at the table. Most matters, however, we handle remotely: tax advice online is no different in substance from a meeting, and the documents go through a secure electronic workflow either way. That is why we work with companies from all over Poland and with foreign entrepreneurs, in English as well.
If you are looking for a tax law firm in Warsaw, you can come in person. If you are looking for a tax advisor online, an e-mail, access to the documents and, when needed, a video call are enough.
Kancelaria Prawna Skarbiec
ul. Maciejki 13, 02-181 Warsaw, Poland
sekretariat@kancelaria-skarbiec.pl
How we work
First contact. You describe your case in the form or by e-mail. We reply in writing: we name the problem, including the one you may not see yet, and propose the form of work: a consultation, written advice, a tax opinion or a tax ruling application. After that reply you know whether the matter needs further work and what we need in order to quote a fee.
Diagnosis and options. We prepare an analysis or an action plan: what you can do, at what risk and at what cost. We recommend, but the decision is yours.
Implementation or defense. We draft applications, letters, agreements and documentation, represent you before the authority and the court, or stay with you as ongoing support.
Not everyone needs a tax advisor on a permanent basis. Sometimes one-off tax advice on a specific decision is enough. Almost every entrepreneur, however, reaches a moment when such help comes in useful, and it is worth knowing where to look for it.
These are the questions we hear most often before a client decides to work with us. We answer them plainly, because a sound decision starts with understanding what kind of help you actually need.
Author: Robert Nogacki, attorney at law (radca prawny, WA-9026), Skarbiec Law Firm. Updated: October 2026.
FAQ: Tax advisory for companies in Poland
What does tax advisory for companies cover?
Day-to-day settlements and the questions that come back every month, but also one-off decisions with major consequences: selling the company, a reorganization, a profit distribution, a cross-border transaction. And defense against the tax authority when a matter reaches the tax office or the court.
The problem a client arrives with often turns out to be a different problem. A question about costs can be a question about corporate structure, and a dispute over an invoice can carry criminal tax risk. You do not need to diagnose anything or know which service you need. Describing the situation is enough.
When is it worth consulting a tax advisor?
Before you make the decision, not after. Tax advice almost always pays for itself before the sale or purchase of a business, real estate or shares, before a change of legal form or method of taxation, before the first transaction with a foreign or related party, before a profit distribution, and immediately after a letter arrives from the tax office, because every day of the deadline counts.
The most expensive tax advice is the advice nobody asked for in time.
Does the tax office really check everything?
No. It does not have the resources. Inspections are selective: IT systems single out taxpayers by anomalies, such as a sudden drop in revenue, an unusual ratio of costs to revenue, an industry classed as high-risk, or transactions with particular jurisdictions.
Two things follow. You can do something wrong for years and never be inspected. When an inspection does come, it will cover several years back and the errors will have compounded. The absence of an inspection is not confirmation that everything is in order.
Why is the tax office questioning something I have done for years?
Because it is allowed to. It was not looking before; now it is. Or it looked and did not notice. Or the interpretation changed, and the office applies the new reading to old years.
That last situation is the most frustrating: you acted in good faith, in line with how the rules were understood at the time, and now it turns out to have been wrong. Is that fair? Not necessarily. Is that how the system works? Yes. That is why the decision trail matters. If you can show that you acted on the state of knowledge at the time (for example on the basis of a tax opinion), you have arguments. Without that trail you are left with a bare assertion against an official backed by the authority of the state.
Why does my friend pay less tax than I do when we earn about the same?
Because the devil is in the details. Legal form, method of taxation, cost structure, the moment revenue is recognized, reliefs: each element changes the final bill.
That does not mean you should copy your friend’s arrangements. Industry, plans, ownership structure and personal circumstances all matter. What is worth doing is asking from time to time whether your current structure is still the right one. It may have been five years ago, when the business was founded, and stopped being so when the business grew.
What should I do if I know I have made a mistake?
You have two options: wait for the tax office to find it, or fix it yourself.
Waiting is a gamble. Perhaps they will not find it; perhaps the matter will become time-barred. If they do find it, they will add interest and may impose penalties. A voluntary correction before an inspection is opened lets you avoid them: you pay the arrears with interest, without a penalty. Where a fiscal offense is involved, voluntary disclosure (czynny żal) may also be available. The longer you wait, the higher the interest, and the harder it becomes to convince anyone of your good faith. Describe your situation in the form below.
Is it worth having a tax advisor on retainer, or is it enough to call when there is a problem?
It depends on the scale and complexity of the business.
A simple service company with few transactions will usually manage with an accountant day to day and an advisor on call for unusual matters. With a complex structure, many counterparties and international transactions, ongoing cooperation makes sense, because an advisor who knows your business will react faster and more accurately than someone seeing it for the first time. We offer that cooperation through a tax retainer or a legal retainer.
There is also a psychological argument. When you know whom to call, you postpone less, and fewer problems grow into crises.
Can I commission a one-off tax consultation?
Yes. A single consultation, opinion or analysis of a specific transaction is billed as a project, and for many clients it is the natural start of a longer relationship. Just bear in mind that a one-off consultation solves the problem you can already see. The ones you cannot see yet are caught only by someone who knows the business day to day.
How much does tax advisory cost?
It depends on the model. Consultations, opinions and applications are usually billed as a fixed fee for a scope of work agreed in advance. Where the scope cannot be predicted, for example during an inspection, we work on an hourly rate with a cap on hours that we do not exceed without your consent. Companies that need an advisor regularly choose a tax retainer. We quote the fee once we know the matter, before we start work.
Any fee is worth setting against the cost of a mistake: the arrears, the interest and the penalty the advice was meant to save you.
Who will handle my case?
One person who is responsible for the whole and knows the history of your business. When the matter calls for a litigator or an accountant, they join the team, but your point of contact stays the same. In tax matters that drag on for years, the greatest losses come not from the substance but from knowledge being handed from one person to the next.
Tax advisor, attorney at law or advocate: whom do I go to with a tax matter?
In Poland, licensed tax advisors (doradcy podatkowi), attorneys at law (radcowie prawni) and advocates (adwokaci) may all advise on tax matters and represent taxpayers before the authorities and the administrative courts. The difference appears when a matter goes beyond tax law: into a dispute with a counterparty, a board member’s liability or fiscal penal proceedings. Then you need a lawyer with litigation rights. At our firm tax advisors work at one table with litigators, so a change in the nature of the case does not mean a change of firm.
Is an online tax consultation possible?
Yes, and that is how most of our matters run today. You send documents electronically, you receive our findings and answers in writing, and when a conversation is needed we hold it by video call. A power of attorney for representation before the tax office can be filed electronically. Where your company is registered matters for which tax office is competent, not for your choice of advisor.
How is the confidentiality of my information protected?
Tax advisors, attorneys at law and advocates are bound by professional secrecy covering everything they learn in connection with your matter. It applies even if you decide not to work with us after the first contact. In particularly sensitive matters we additionally use non-disclosure agreements and a segregated document workflow.
Entrust us with your case
Describe the situation briefly: what has happened or what you are planning, which tax the matter concerns, and whether proceedings are already under way. We usually reply within one business day, in writing: we name the problem, indicate what form of help it needs, and tell you what we need in order to quote a fee.
Taxes are certain. Mistakes in taxes do not have to be.
