Information about our Team
The Tax Litigation Team is a team of experts within the Tax Department of PricewaterhouseCoopers whose services consist of:
- assisting Clients during tax and fiscal controls as well as in their contacts with the tax authorities at all levels, including proceedings before administrative courts;
- preparing applications and handling matters in respect of binding rulings of the tax law as well as advanced pricing arrangements (APA);
Our Team is composed in the most part of tax or legal advisors who are among the best specialists and who combine an in depth knowledge of Polish tax proceedings with many years experience in contacts with the fiscal and tax administration.
Our specialisation
Our Team provides litigation services within the scope of tax proceedings and proceedings before administrative courts. Our services cover issues concerning all the taxes functioning in Poland, including: personal income tax, corporate income tax, value added tax (VAT), excise, local taxes, fees and customs, if they are the subject of disputes with the tax or fiscal authorities, as well as all kinds of obligations to which the provisions on tax proceedings apply, such as the obligations provided for by the Act on Prices. Within the scope of customs proceedings, members of our Team cooperate with the Customs and International Trade Team.
Our current cooperation with specialists from the industrial teams of the PricewaterhouseCoopers Tax Department ensures that the advice and argumentation which we present before the tax authorities and the administrative courts is of a high level. Our Clients are, first and foremost, companies from the pharmaceutical, tobacco, petroleum, telecommunication and computer industries, as well as manufacturers of branded consumer goods and chains of retailers. The numerous cases we have won on behalf of our clients before the tax authorities as well as before the administrative courts constitute a measurable result of the services rendered by our Team.
Detailed scope of our services
Below we present a description of the services rendered for our Clients:
Tax control, tax procedures and procedures before administrative courts:
- assistance in preparing our Clients for tax and fiscal controls, including an analysis of the tax obligations, the documentation possessed by the Client and the Client’s internal procedures;
- tax advisory services related to tax control / fiscal control / tax proceedings which have already been initiated ,
- preparation of letters and applications for the purposes of tax control / fiscal control and tax proceeding at all levels, in particular: reservations relating to, and explanations to, protocol, appeals against decisions, applications for assessing overpayment of tax as well as other letters required during proceedings;
- tax advisory services related to extraordinary modes of questioning tax decisions, in particular with respect to the cancellation of a decision and re-initiation of proceedings, as well as preparing appropriate applications and conducting the proceedings in this respect;
- tax advisory services related to proceedings before administrative courts, in particular, the preparation of complaints against the decisions of provincial administrative courts and other letters in the course of proceedings, as well as representing our Clients during the hearings before administrative courts;
- preparing complaints to the Supreme Administrative Court against the verdicts of provincial administrative courts;
- representing the Clients based on powers of attorney granted, at each level of the tax control and tax proceedings as well as proceedings before the provincial administrative court and the Supreme Administrative Court;
- consultation on the contents of letters prepared by the Clients in the course of the proceedings;
- preparation of tax opinions related to:
- tax procedures;
- matters related to the creation, expiry and securing of tax obligations;
- matters involving fiscal penal liability and fiscal penal proceedings, within the scope of tax advisory;
- matters involving the liability of collective entities;
- matters involving enforcement proceedings conducted against the Clients.
- reviews of the Clients’ internal procedures aimed at mitigating risks related to the liability of collective entities.
Binding rulings of the tax law and advanced pricing arrangements (APA):
- preparing applications in respect of binding rulings of the tax law and supervising the matters in order to receive the fast possible response which is also satisfying;
- comprehensive assistance in proceedings related to advanced pricing arrangements between taxpayers and the tax authorities (APA);
- initiating mutual agreement procedures as a separate mode of tax procedure aimed at eliminating double taxation;
- filing applications to tax authorities for binding rulings on the tax law in respect of an interpretation of the provisions of double tax treaties;
- assisting in receiving a reimbursement of overpaid withholding tax;
- assisting in receiving certificates of residence (in cooperation with foreign offices).
Training courses:
Training courses organized by our Team are not only of a theoretical but also of a practical nature. We offer a variety of training courses encompassing a wide range of issues, including:
- Recent amendments to the Tax Code;
- Recent amendments to the Fiscal Penal Code as well as the Act on Liability of the Collective Entities;
- Rights and obligations of the parties during a tax control and tax proceedings.
Our contacts
If you are interested in the offer of the Tax Litigation Team, please do not hesitate to contact:
Mariusz Marecki
Director
tel. +48 (22) 523 47 87
faks. +48 (22) 508 4787
e-mail:
mariusz.marecki@pl.pwc.com
Miros³awa PrzewoŸnik-Kurzyca
Manager
tel. +48 (22) 523 48 60
fax. +48 (22) 508 48 60
e-mail:
miroslawa.przewoznik-kurzyca@pl.pwc.com
