International taxation

International taxation

The tech industry is international by nature. Cooperation with foreign businesses, international licenses and high mobility of IT specialists or engineers are part and parcel of the industry, or even the basis of its operation. The international nature of business also has consequences in terms of taxes. Payment of dividends, interest or royalties to foreign entities, the acquisition of services from related foreign entities or cooperation between foreign entities with IT consultants or engineers residing in Poland requires knowledge of concepts such as withholding tax, shifted income, tax establishment, tax residence or centre of vital interests.

International tax regulations are frequently modified to adapt those introduced many years ago to the rapidly evolving business model of the technology industry. Due to the complexity of international tax regulations and the frequent changes in them, more and more time is required to ensure not only the compliance of the business model with the requirements of tax law but also the effectiveness of this model.

Being aware of how entrepreneurs need to focus their attention on their core business, the Tax Kraft team offers clients comprehensive support in dealing with the international tax aspects of business.

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    Our team has many years of experience in tax advisory for international businesses (in practically every industry) operating in Poland, the Scandinavian countries and the Baltic countries. Members of our team have frequently advised Swedish companies investing in Polish or Lithuanian entrepreneurs to choose Poland as their starting point for international expansion. We also assist Polish entrepreneurs in tax matters related to expansion into Scandinavian markets.

    How can we help?
    • we support entrepreneurs in analysing obligations relating to withholding tax payments, including determining the beneficial owner of a payment, applying the pay-and-refund procedure or obtaining an opinion on the preferences applied.
    • we help clients analyse the tax aspects of the international relocation of employees or subcontractors.
    • we help foreign entities determine the tax consequences of cooperation with employees or subcontractors residing in Poland, including with regard to risks associated with setting up a permanent establishment in Poland.
    • our team supports clients before their expansion into foreign markets and once they are already operating in these markets (e.g. in selecting the appropriate legal structure, organising financial and goods flows, and conducting tax residence analyses).
    • in addition, we effectively identify which entities in a group may be subject to regulations concerning controlled foreign companies (CFCs) and determine whether such companies conduct genuine and significant business activities. Our team will review whether registration obligations are fulfilled and relevant registers required by Polish regulations are kept, as well as whether reporting and tax obligations under CFC regulations are fulfilled.