International business involves the overlap of different tax systems, divergent practices of authorities, and regulations that are often inconsistent. Decisions regarding group structure, financial flows, tax residency, or how to operate in other jurisdictions directly impact the level of risk, tax costs, and long-term business stability.
We support clients in organizing the international tax aspects of their operations in a way that aligns with their actual business model. We combine domestic law, international regulations, and the practice of authorities, helping clients make decisions that are defensible both locally and in cross-border relations.
How We Help in the Area of International Tax Law?
Tax Residency and Place of Taxation
We advise on determining the tax residency of individuals and entities and the principles for taxing income earned in different jurisdictions.
Cross-Border Transactions and Structures
We analyze the tax effects of international transactions, including financial flows, restructurings, and investments made outside of Poland.
Double Taxation Agreements
We support clients in applying and interpreting international agreements, including the qualification of income and the selection of the appropriate country for taxation.
Transfer Pricing and Intra-group Settlements
We provide advice on the tax aspects of transactions between related entities in different countries, considering risks and documentation requirements.
Holding Structures and Cross-Border Operations
We help design and assess holding structures and models for conducting international operations from a tax perspective.
International Tax Disputes and Proceedings
We represent clients in tax cases with a cross-border element, including dealings with foreign authorities.
Scope of Support
- Income earned internationally from multiple sources
- Risk of double taxation
- Change in tax residency of individuals or entities
- Transactions with foreign contractors or related companies
- Financial flows and settlements within international groups
- Application of double taxation agreements
- Foreign expansion and holding structures
- Cross-border tax proceedings
Are You Operating or Investing Abroad?
Let’s discuss the best solution.

Managing partner, attorney at law
+48 512 243 919

Senior counsel, attorney at law
+48 530 025 037

