PricewaterhouseCoopers has the largest Tax department of any professional services firms in Poland. PricewaterhouseCoopers is one of the few consultancy practices operating on the Polish market to base its service structure on industry specialisation. We believe that not only proficiency in legal and tax issues, but also in-depth knowledge of the particular business sector is necessary to provide comprehensive, high quality advice to our Clients.
In order to meet the growing demand for tax advisory services in the real estate sector PricewaterhouseCoopers has established a team of specialists within the Tax department. The Real Estate team is dedicated solely to serving Clients from the real estate sector and has gained extensive experience in tax and legal matters relating to real estate projects through close involvement in a variety of assignments undertaken in Poland by Clients from this industry sector. We are able to combine specialists who understand the industry and, at the same time, offer a high level of competency in tax and legal matters, experience in devising the best practices and proficiency in delivering high quality advice tailored to meet the Client's needs. Advisory services provided by the team have often resulted in significant taxation benefits for our Clients.
Our real estate specialists have participated in numerous projects, which demanded a complex knowledge of the tax, legal and business issues connected with real estate investments. Thanks to the long-lasting involvement in the real estate sector, we have worked out a tax methodology, procedures and industry focused products dedicated to providing assistance to our Clients and solving complex issues, as well as to mitigate the tax risks resulting from inconsistent judgments, practice and interpretations of the Ministry of Finance, both for investors and for their Clients.
- structuring of income fluctuation for accounting and tax purposes for entities engaged in long-term construction contracts
- reviewing and optimising the VAT position through the application of our planning ideas for recovery of input VAT and VAT compliance during the construction phase
- reviewing and optimising the VAT burden on real estate investments undertaken by entities making VAT-exempt supplies
- structuring of greenfield, turn-key projects, etc. in the light of the Polish VAT regulations
- structuring of projects which involve re-building, renovation or demolition of existing constructions, including providing advice on the proper establishment of a base for tax depreciation, transfer of technical (e.g. telecommunication, power, gas, sewerage, heating, water supply) infrastructure
- assisting in the classification of investment expenditure (to be capitalized into value of investment or directly expensed)
- tax treatment of pre-development costs
- analysing tax efficient financing of development processes (own capital vs. external financing, including leases)
- preparing financial projections of real estate investments in Poland from the perspective of Polish tax implications
- reviewing the classification of real estate for the purposes of calculating real estate tax (buildings, structures, etc.)
- carrying out analyses of the indirect tax (civil law activities tax, VAT) implications of real estate transfer transactions
- reviewing and optimising the tax depreciation of real estate for both investors and end users of developed real estate, in particular
- analysing investment expenditure and planning potential tax and cash flow savings
- providing assistance in reviewing and optimising the initial value of real estate
- carrying out various analyses related to accelerating or deferring the depreciation of real estate
- reviewing and optimising the tax liabilities using tax depreciation planning techniques
- optimising the tax savings based on the assets segregation concept
- reviewing and optimising the financial costs of real estate development
- providing assistance in the preparation of underlying documentation related to the investment process
In the process of global or local restructuring of the Client's organisation, we can offer a review to identify the most tax efficient structure and the optimum acquisition/transformation scenario which includes cross-border implications and meets your needs. We can also provide strategies regarding the pre-acquisition or disposal reorganisations, purchase price structuring, review of the tax efficiency of financing structures - taking into account the most favourable choice of jurisdiction for financing vehicles, and tax impacts of the chosen financing structure on the Client's business.
We can provide a detailed review and analysis of the target company's tax position. The areas of our analysis include tax compliance, contingent tax liabilities and risks resulting from there, transfer pricing, identification of risk areas and tax planning opportunities.
Following an acquisition, we can assist in solving complex issues concerning the new organisational structure, including financing strategies and tax planning. Our expertise includes such projects as mergers, take-overs or privatisations. Our consultants have participated in numerous projects of this kind, both at their early stage (initial assessment of the tax and legal position of the company) as well as playing the role of lead tax advisors in such transactions.
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