Mitigation of tax risks (MDR, TP, GAAR)

It is far better to secure yourself with effective advisory services than to extinguish a tax fire.

Our professional experience shows that tax risks continue to grow, with no real prospects for change in this area. Chaotic and inconsistent changes in regulations, setting tax traps, shifting additional responsibilities onto taxpayers, a pro-fiscal interpretation of the law, and unstable tax jurisprudence – these are the challenges all entrepreneurs face. As experienced tax advisors, our role is to inform you of the risks and find ways to mitigate or neutralize them.

The greatest risk comes from anti-tax avoidance clauses. Whether it's the general GAAR clause or specific SAAR clauses (e.g., related to the neutrality of mergers, divisions, and share exchanges, or operations in SSE/Investment Zones).

Closely related to these clauses are the rules on reporting tax schemes (MDR). The very broad definitions cover a wide range of events and actions, meaning that many ordinary tax-related activities are subject to mandatory reporting. In this area, we offer not only audits but also training and the implementation of internal MDR procedures.

Both GAAR and MDR apply to related entities, impacting transfer pricing (TP) risks. That’s why we take a comprehensive approach to these groups of regulations and the obligations and tax risks they entail. In our view, only such an approach provides the proper protection for our clients.

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Michał Zając
Partner, Tax Advisor, Lawyer
605 102 600 m.zajac@kancelaria-wz.pl
Michał Wojtas
Partner, Tax Advisor, Succession Advisor
664 993 396 m.wojtas@kancelaria-wz.pl