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Success of Rödl & Partner Wrocław – an effective tax adjustment brought a refund of 400 thousand zloty

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​​​​​​​​​​​​​​​​​​​​​Daria Walkowiak-Dobner and Łukasz Peterek from our Wrocław office can boast a spectacular success. In less than half a year, they have substantiated in Poland the legitimacy of an additional assessment of almost 500 thousand euro by foreign revenue authorities, thus eliminating the risk of double taxation of their clien​t.




The case concerned adjustment of income of a German company and its Polish branch office between 2018 and 2021. German revenue authorities questioned the EBIT achieved by the Polish branch office claiming that it was overstated in view of the branch’s functions and risks.

Our job – the key step was to apply for a unilateral adjustment to the Ministry of Finance, which helped to eliminate double taxation. We filed the application in August 2024 and got back a favourable decision as soon as December – this is one of few rulings issued in this procedure in Poland.

Effects?

  • Adjustment of 445 thousand euro, that is more than 2 million zloty in assessed expenses.
  • Tax refund of nearly 400 thousand zloty for both shareholders.
  • Fast-track procedure – Finance Ministry’s decision delivered in just 4 months.
  • Key effect achieved just before the 2018 accounts became time-barred.

This is yet another proof that Rödl & Partner’s experts effectively support clients in international taxation affairs finding successful solutions even in the most complicated cases.



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Aleksandra Pilecka

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