In many business situations, the issue is not the lack of regulations, but their ambiguity. Planned transactions, structural changes, new settlement models, or unusual operational events often require confirmation of the correct tax classification in a specific situation. An individual tax interpretation helps reduce the risk of disputes and sanctions, providing formal protection when implementing planned actions.
We support clients in consciously using the institution of individual tax interpretation. From assessing whether an interpretation is the appropriate tool, to preparing the request, and taking further actions if discrepancies arise with the authorities’ position. Our goal is to secure business decisions in a way that works in practice and has a real impact on entrepreneurs’ activities, rather than just serving as a formal confirmation of regulatory interpretation.
How We Help with Tax Interpretations?
Assessing the Need for Interpretation
We analyze whether a tax interpretation will provide real protection and whether it is the best solution considering the risks and planned actions.
Preparing Interpretation Requests
We draft requests precisely and defensively, ensuring proper description of the facts or future events and consistency in the argumentation.
Legal Argumentation and Taxpayer’s Position
We build justifications based on regulations, case law, and the practices of authorities, taking into account potential interpretative directions.
Interpretations for Transactions and Reorganizations
We support securing the tax effects of transactions, restructurings, ownership changes, and significant corporate decisions.
Interpretations in Group and International Structures
We advise on issues related to intra-group settlements, tax residency, and cross-border transactions.
Reaction to Unfavorable Interpretations
We analyze issued interpretations and recommend further steps, including challenging divergent positions of the authorities or changing the adopted business model.
Scope of Support
- Support in resolving doubts about tax implications
- Decisions requiring confirmation of the authorities’ position
- Transactions or reorganizations with elevated tax risk
- New or non-standard business models
- Divergent approaches by authorities to similar factual situations
- Risk of challenging the adopted settlement model
- Received interpretations that raise doubts or require action
- Need for formal protection before implementing a project
Do You Have Doubts About the Tax Implications of Planned Actions?
Let’s discuss the best solution.
Managing partner, attorney at law
+48 512 243 919
Senior counsel, attorney at law
+48 530 025 037