For foreign-owned businesses and international groups
Make informed decisions about how your business is owned, financed and operated across borders.
Assess your Polish business within its international context. Compare structural options, understand the implications and move forward with a written recommendation and an implementation roadmap.
Poland-focused analysis · Defined project scope · Written recommendations
Structuring Review & Roadmap
A defined advisory project, not just a consultation call.
The engagement
International tax and corporate structuring is the assessment and design of how a business is owned, financed and operated across jurisdictions. It brings together ownership arrangements, tax consequences, governance and the practical requirements of running the structure.
For a business connected with Poland, this means examining how its Polish operations interact with foreign shareholders, group companies and cross-border payments.
A project may concern one planned transaction or a wider group structure. Incorporation, tax filings and implementation are separate workstreams unless expressly included.
Your starting point
Start with the business decision. The scope of the analysis should follow from it.
01
You need to decide how to establish and organise Polish operations within an existing international business.
02
Your companies and shareholders are in different countries, and you need to assess how ownership and distributions work together.
03
Related companies provide funding, services or intellectual property to each other.
04
You are bringing in an investor, reorganising ownership or preparing for a future disposal.
The central deliverable
A written basis for your next business decision.
The core engagement examines an agreed structural question and produces a documented recommendation. The depth of analysis and deliverables are defined before work begins.
A written recommendation can also conclude that the existing structure should be retained or that a proposed change should not proceed.
The relevant entities, ownership relationships, business activities and transaction flows, based on the information reviewed.
Feasible approaches compared against the business objective, including tax implications, commercial requirements and practical limitations.
A reasoned recommendation with key assumptions, trade-offs and matters requiring further confirmation.
Material issues identified within scope, including information gaps, specialist input and foreign-law questions.
The sequence of actions, dependencies and workstreams needed to implement the selected approach.
Detailed calculations, formal opinions, legal documents, filings and implementation support are included only where specified in the engagement.
Analysis scope
Each project combines the workstreams relevant to the decision. The following areas are not automatically included in every engagement.
How should ownership and control be organised?
Assessment of direct and indirect ownership, holding arrangements, governance requirements and implications for distributions or future ownership changes.
How should the Polish operation fit into the wider business?
Comparison of relevant operating arrangements, including subsidiary and branch options, responsibilities, compliance requirements and interaction with foreign entities.
What should be checked before money crosses borders?
Assessment of relevant dividends, interest, royalties and service payments, including applicable withholding tax (tax deducted by the payer on certain payments) rules, treaty or exemption conditions and supporting evidence.
How should related companies fund and transact with each other?
Review of financing, service arrangements and cost allocations, with identification of arm’s-length considerations and any documentation or specialist analysis required.
Where could the business have tax obligations?
Assessment of management, people, functions and operating arrangements that may affect residence, permanent establishment exposure and the credibility of the proposed structure. A permanent establishment is a taxable business presence that may arise in another country without incorporating a local company.
What should change before an investment or ownership event?
Assessment of proposed ownership changes and reorganisations, including their tax implications, dependencies and sequencing.
Comparing the options
A lower headline tax rate does not, by itself, make a structure suitable. The assessment considers the combined effect of tax, implementation, administration and commercial requirements.
| Decision factor | What the review considers |
|---|---|
| Business purpose | Whether the arrangement serves a genuine operating, ownership or financing objective. |
| Tax consequences | Relevant tax treatment, relief conditions and potential exposure within the agreed scope. |
| Substance and governance | Where decisions are made, activities occur and responsibilities sit. |
| Implementation | Required steps, dependencies, advisers and one-off work. |
| Ongoing cost | Accounting, reporting, administration and maintenance requirements. |
| Future flexibility | Implications for distributions, investment and later ownership changes. |
Working together
01
Share your business context, the countries involved and the outcome you are considering.
02
Confirm the questions, entities, jurisdictions, documents, deliverables and responsibilities covered by the project.
03
Analyse the relevant information and consolidate factual questions in writing.
04
Assess feasible approaches and discuss the implications and trade-offs.
05
Provide the agreed written output and explain the proposed next steps.
06
Proceed with separately scoped corporate, accounting, tax and other specialist work.
The work combines document review, consolidated written questions and focused discussions at key decision points. You can begin by sending a written project brief.
Practical questions
Illustrative scenarios, not client case studies.
Local context, clear responsibilities
BIZ PARTNER works with foreign entrepreneurs and internationally connected businesses in Poland. Its accounting support and corporate and commercial work provide relevant local context when assessing how a proposed structure would operate in practice.
A structuring engagement should connect the recommendation with the records, agreements and ongoing obligations needed to support it.
The engagement identifies the jurisdictions covered, the work included and any additional professional input required. Foreign-law analysis and formal tax or legal opinions must be assigned to appropriately qualified professionals within the agreed scope.
Scope and fees
Fees depend on the question being assessed, the number of entities and jurisdictions, transaction complexity, the quality of available information and the specialist input required.
The proposal sets out the scope, deliverables, fees, responsibilities and exclusions before substantive work begins.
For ongoing Polish tax obligations, see our tax consulting services. The proposal defines the actual work included in your engagement.
FAQ
Yes. A project can review an existing structure, assess a planned change or focus on a specific transaction. The need for changes depends on the findings.
Not necessarily. A Polish company with foreign shareholders, overseas activities or planned cross-border payments may have a defined structuring question worth assessing.
No outcome can be guaranteed in advance. The review considers tax consequences together with commercial purpose, implementation costs and ongoing obligations. Retaining the existing structure may be the better option.
Only the jurisdictions and questions expressly included in the scope. Foreign-law conclusions may require separate input from appropriately qualified local professionals.
Document collection and factual questions can usually be handled in writing. Focused discussions may still be required to confirm objectives and explain the recommendation.
Usually an ownership chart, a description of business activities, the countries involved, relevant financial information, key agreements and details of the proposed decision. A tailored document list follows the scope discussion.
Registration alone does not establish the factual business presence relevant to every tax question. The assessment may consider actual activities, decision-making, people, resources and the rules applicable to the arrangement.
Only if expressly agreed. Advice and recommendations are distinguished from legal documentation, registrations, filings and other implementation work.
Start with your decision
Describe the business decision, the companies involved and the countries connected to it. This gives us a starting point for defining the appropriate scope.
Contact BIZ PARTNER