tax advisers

Legal500 emea leading firm 2021 Legal500 emea top tier firms 2021 Legal500 firm 2020 Legal500 individual 2020 Leading firm Leading individual


Legal500 firm 2020 Legal500 individual 2020
Leading firm Leading individual


The latest edition of the Insolvenzrecht commentary published by C.H. Beck is now available

We have a pleasure to announce that the latest edition of the Insolvenzrecht commentary published by C.H. Beck is now available.
It is a compendium constantly updated by 70 authors, and Marcin Zimny, alongside his distinguished colleagues Anna Maria Miller, Emilia Pienicka, LL.M., dr Aleksandra Krawczyk, LL.M. corp. restruc., is honored to comment on the tax aspects of restructuring and bankruptcy in Poland.

Marcin Zimny ranked second among top tax advisors.

It is our great pleasure to inform you that Dziennik Gazeta Prawna has just announced the results of the 16th Ranking of Tax Firms and Advisors and Marcin Zimny was ranked second among top tax advisors in the Excise category.

ZIMNY Doradcy Podatkowi placed among the top tax advisory firms in 2021 by Dziennik Gazeta Prawna

We are pleased to announce that in the 16th Ranking of Tax Firms and Advisors published by Dziennik Gazeta Prawna, ZIMNY Doradcy Podatkowi was placed among the top tax advisory firms in 2021.

ZIMNY Doradcy Podatkowi among BEST LAW FIRMS 2022 according to Forbes magazine.

We are pleased to announce that in a report published by Forbes magazine, ZIMNY Doradcy Podatkowi was included in the group of BEST LAW FIRMS 2022. The list is based on recommendations from lawyers working in other law firms and business clients. Thank you very much for your recommendations.

Marcin Zimny awarded by Dziennik Gazeta Prawna

Marcin Zimny was selected by Dziennik Gazeta Prawna as one of the leading tax advisers in the 13th
Tax Ranking of Companies and Tax Advisers.


philip morris
Polski Fundusz Rozwoju grupa pfr logo
CGR international
Phyto Pharm
Polski Fundusz Rozwoju grupa pfr logo
CGR international
Phyto Pharm
Coast2Coast capital


  1. Support in the sale and purchase of companies
    If you are thinking of selling your company, we can show you the optimal sales structure.
    Read more

    On the other hand, if you are looking to buy a company, we will prepare the most effective way to
    integrate the acquired company with your current structure, and the formula for financing the
    acquisition of the company.

    As part of a tax due diligence investigation, we will notify you about any tax risks related to the
    acquisition or sale of a certain company, and can prepare suggestions on how best to fix the status of
    companies burdened with tax risks.
    We will protect your interests during negotiations regarding the purchase agreements for these
    We will help you to contact potential investors, or companies looking for investors.
    Recently, we have assisted in the purchase of several businesses dealing with food production and
    the paper business in Poland.

    Marcin Sroga, Marcin Zimny

  2. Excise refund on electricity
    We will start off by determining whether your company is entitled to an excise tax refund on electricity.
    Read more

    Then we will guide you through the whole process of the excise tax refund. The statutory auditor will
    determine the amount of the excise duty refund and then we will prepare all necessary documents
    and the application for excise tax refund. We will also represent your company in this respect before
    the tax authorities.

    Thanks to our many years of experience, including in front of the customs authorities and the Ministry
    of Finance, as well as our commitment to our clients, we will efficiently carry out the excise tax refund
    process. In addition, we are the authors of the latest commentary to the Excise Duty Act on the
    market: link
    Marcin Zimny is also a tax adviser specialising in excise tax and recommended by the Rzeczpospolita

    Marcin Zimny

  3. 50% of tax deductible costs for employees
    Introducing the possibility to apply 50% of tax deductible costs to salaries under employment
    contracts is very beneficial for the employees and the employer, but if it is not done properly, then
    there is a considerable tax risk.
    Read more

    We can help you implement this solution in a way that will reduce or
    eliminate the tax risk. If you already use 50% tax deductible costs, we can verify whether the adopted
    solutions are exposed to any risk, and if so, we will help minimise it.
    After reviewing the current situation, we will suggest possible amendments to employment contracts,
    work regulations, or the rules of recording created works. We would typically prepare an application
    for an individual tax interpretation and then, after obtaining a favourable interpretation, we would
    supervise the implementation of the recommended solution.
    Recently, we have comprehensively supported a large company employing several dozen IT
    specialists in this area.

    Karolina Donowska


  4. Documentation of transfer pricing
    We can prepare transfer pricing documentation for your company, whether it operates locally or within
    international capital groups.
    Read more

    We will also prepare a benchmark allowing us to justify the marketability
    of the agreed remuneration in a transaction with a related entity.
    We will help you determine the way and conditions of settling transactions with related parties,
    including the development of transfer pricing policy in your company.
    Thanks to our many years of experience and support, you will strengthen the tax security of your
    We recently prepared transactional documentation for international capital groups as well as for
    entrepreneurs operating exclusively on the Polish market. We documented transactions concerning
    the supply of materials for production, the supply of finished products, and the supply of components
    for further processing, as well as services of low added value, sales brokerage services.

    Arkadiusz Duda, Marcin Sroga

  5. Applying tax relief in connection with R&D activities
    If you are performing research and development work, we can help you to take advantage of
    additional deductions from your revenues of certain costs incurred for research and development.
    Read more

    We will help you to effectively use your tax relief applicable for research and development. We will
    identify the areas covered by it and assist you with making settlements.
    The area of tax relief for research and development is currently being extended – the legislator is
    introducing new relief or modifying existing relief, which will allow you to gain benefits not only at the
    time of investment, but also throughout the period of using the developed innovations (innovation

    Marcin Zimny, Arkadiusz Duda

  6. Family Office
    We can help you with selecting and changing tax residency, establishing a family foundation,
    selecting the most tax-effective form of conducting business activity, or in setting transfer prices in
    transactions between your companies.
    Read more

    We will comprehensively support you in the succession of your business not only in terms of taxes,
    but also in other areas, as we cooperate with investment advisors, investment funds, managers,
    lawyers and statutory auditors.
    We will also help you to protect your assets against any legal and tax risks related to your business.

    Marcin Zimny

  7. Comprehensive assistance and representation before tax authorities, law enforcement agencies and courts
    We will assist you at every stage of proceedings before tax authorities, leaving you to focus on
    continuing your business.
    Read more

    We will also support you in proceedings before the administrative and
    common courts, making every effort to ensure that the proceedings are successful.

    At the same time, we will advise you on how to ensure the protection of your assets and your
    company, so that even a negative scenario of closing proceedings does not have a significant impact
    on your projects. In this respect, we will take action to eliminate or reduce the negative effects of
    administrative enforcement.
    We have a wealth of experience in conducting proceedings before tax authorities and administrative
    courts in the field of VAT, PIT, CIT, excise duty and customs. Members of our team have taken part in
    hundreds of proceedings, with the value of the disputes in some cases running into the tens and
    hundreds of millions of zlotys. In particular, we have successfully completed many VAT proceedings
    related to abuses of rights by our clients' contractors, which carried a high tax and criminal fiscal risk
    for clients.
    We were also successful in a dispute concerning excise tax, amounting to around PLN 200 million.
    We can ensure the defence of the individuals responsible for tax settlements in your company,
    namely members of management boards, financial directors and chief accountants against possible
    fiscal criminal liability.
    In this respect, we managed to get the person responsible for tax settlements acquitted due to the
    improper application of a tax exemption; we negotiated penalties favourable for the client under
    conciliation procedures.
    In conclusion, with our extensive experience and comprehensive support, thanks to our assistance
    you will enjoy the peace of mind and continuity of business, despite any ongoing proceedings.

    Karolina Donowska, Marcin Zimny (litigation, enforcement) Marcin Sroga (KKS)

  8. Tax planning and tax security
    Restructuring, preparing a scenario for the planned business activity of a capital group, changing the
    method of financing and other changes – whether in a company or in the case of an individual
    business/ sole proprietorship – are multi-stage activities that have different tax consequences.
    Read more

    As part of the service, with regard to tax issues we prepare a restructuring scenario, a scheme of
    conducting planned activities, carry out necessary tax due diligence audits and monitor the tax
    aspects of the transaction.

    Marcin Sroga, Marcin Zimny


Pharmaceutical sector

As part of our services for the pharmaceutical sector, we offer advice and support by specialists who
know the market and applicable tax regulations. Our associates have advised the world's largest pharmaceutical corporations.
We advise in particular on the following issues:

  •  how to manage the supply chain of medicinal products and medical devices in a tax-efficient way,
  •  the use of ethyl alcohol in the manufacture of medicinal products, active substances and food supplements,
  •  tax due diligence aimed at identifying typical tax risks occurring in the industry (e.g. VAT rate),
  •  restructuring economic activity,
  • granting licences,
  • contracts with hospitals and research centres, as well as with doctors involved in clinical trials, including the most tax-efficient form of cooperation with doctors,
  • classification of medicinal products, medical devices and dietary supplements for tax purposes,
  • the application of an exemption from excise duty on alcohol used in the manufacture of medicinal products and active substances,
  • setting up tax warehouses and other activities requiring excise duty authorisation.

Our associates advised the world's largest pharmaceutical corporations.


Construction, real estate and infrastructure

We support domestic and foreign investors in dealing with all tax issues related to housing,
commercial and infrastructure construction, including the construction process, real estate trading and infrastructure.
We advice clients on the following issues:


  •  taxation of income from real estate investments,
  •  taxation of real estate trade with indirect taxes (VAT, tax on civil law transactions),
  •  selection of the optimal ownership structure for investments in the real estate market in terms of tax efficiency, taking into account the specifics of investments in non-residential and residential real properties,
  • tax aspects related to the execution of infrastructure works, as well as their transfer to local municipalities
  • taxation of alternative forms of investment finance,
  • constructing an optimal formula for tax depreciation,
  • tax aspects related to investments made as part of PPP,
  • taxation of leasing and rental of real estate,
  • settlement of expenditures and operating costs of real estate,
  • real property tax.

Our co-workers have worked for several leading developers and the largest provider of technical
network services in Poland.

New technologies, digital economy, telecommunication, cryptocurrencies

In our practice, we provide specialist services to companies from the digital economy sector, in particular:

  • tax support for start-ups from the very beginning,
  • we advise in choosing the most tax-effective legal and organisational form of conducting business activity, including its international aspects,
  • we advise in selling investments,
  • we review e-commerce activity regarding the operation of foreign plants,
  • we assist in determining the place of supply of services for VAT purposeswe analyse transactions from the point of view of withholding tax applicable on licence fees and data processing,
  • we verify the moment of recognition of revenues and costs,
  • we implement tax relief for R&D activities,
  • we help apply 50% of tax deductible costs to employee salaries in connection with the transfer of copyrights,
  • we support the tax settlement of transactions with using cryptocurrencies, including the use of tax jurisdictions outside Poland,
  • we deal with tax planning in terms of obtaining financing through ICO,
  • we support projects involving the commercialiation of intellectual property.

We also have extensive experience in advising telecommunications companies in the area of propert tax. Our associates have worked for the largest telecommunication companies in Poland and the
largest domestic provider of technical networking services. We have represented businesses from the new technology sector during tax audits and before administrative courts.

Insurance and banking (financial services)

We offer advisory services for entities operating in the broadly understood financial sector, in particular in banking, insurance, investment funds and capital markets.
We provide industry-specific, pragmatic tax advice, and we particularly specialise in the following areas:

  • receivables trading, including sales to securitisation funds,
  • advice on setting up branches or transferring the existing business of a legal entity to a branch or vice versa,
  • verification of the correctness of tax calculations made by certain financial institutions,
  • the analysis of transactions consisting in trading in securities and financial instruments,
  • the implementation of solutions securing persons managing financial institutions for fiscal criminal liability,
  • the implementation of structures optimising tax settlements in the area of income tax and VAT, taking into account business operations within a consortium,
  • verification of the VAT calculation methodology,
  • withholding tax issues on royalties and intangible services,

Our associates have worked for leading banks and insurance companies.
We cooperate with http://www.beinsured.pl/, the largest portal for insurance companies, where we regularly publish tax advice and explanations.


We have extensive experience in cooperating with companies from the automotive industry.
Companies from the automotive industry, investing in Poland, can quite often count on support from public funds. This is because production plants are usually located in special economic zones (SEZ).
Therefore, we advise on the tax aspects of investing and conducting business in SEZ. In addition, we also offer advice regarding:

  • the tax aspects of licensing and the transfer of know-how relating to the production of vehicle parts and equipment,
  • tax exemptions on research and development,
  • the organisation of the supply chain, in particular to ensure tax-efficient supply chain management,
  • excise, duties, transfer pricing and VAT in various aspects of business activities in the automotive sector.

We prepared transfer pricing documentation and developed a procedure for conducting chain/trilateraltransactions for several leading companies in the automotive industry. 

We have provided tax advisory services for car concerns, manufacturers of car parts, also operating in SEZ.



We have extensive experience in cooperation with FCMG companies, for which we provide the following services:

  • tax planning,
  • current income tax and VAT settlements,
  • global and local employment,
  • disputes resolution,
  • remuneration and benefit systems,
  • legal advice (mainly concerning the organisation of the structure of affiliated companies),
  • all tax and customs aspects of commercial transactions,
  • tax structuring and restructuring, protection of financing and acquisitions, as well as the representation of businesses in disputes with the tax authorities.

In addition, we have prepared procedures for conducting chain transactions, models of cooperation between producers and sales networks; we have established and managed tax warehouses.
Our associates have worked for FMCG market leaders and are fully in tune with the workings of the industry.

Investment funds

We provide financial institutions with industry-specific tax advice regarding:

  • tax structuring of investments,
  • mergers & acquisitions and joint ventures,
  • real property portfolio management,
  • global and local employment, including the design of incentive schemes,
  • fiscal criminal law, including the liability of collective entities,
  • conducting tax proceedings and resolving disputes,
  • tax planning,
  • tax due diligence,
  • tax aspects of equity transactions,
  • human resources and PIT management,
  • debt restructuring.

We ensure the tax security of transactions involving the acquisition of shares and other assets.
We have advised on numerous transactions, prepared the structure of company acquisitions on the tax side and the settlement of these acquisitions, advised on the drafting of share sale agreements,
and have supervised the tax and legal side of debt restructuring.

Fuel sector

We provide tax advisory services regarding the fuel industry, including in the following areas:

  • infrastructural investments,
  •  national and international trading in fuels for vehicle propulsion and heating purposes,
  • developing security procedures for companies involved in trading and transporting fuels
  •  applying excise relief and reduced excise rates
  • in disputes before tax authorities and administrative courts regarding VAT, excise duty and CIT.
  •  With regard to excise tax, customs duty, VAT, international tax planning, fuel surcharge and real property tax.

Our associates have advised the largest Polish and foreign companies involved in the production and
distribution of fuels.

Gas industry
We advise gas industry companies on the following aspects:

  • the process of initiatign and continuing gas production investments
  •  gas import and storage
  •  joint ventures


  1. Excise

    We provide services to companies in the energy, pharmaceutical and FMCG sectors concerning
    excise tax and fuel surcharge. Our advice includes in particular:

    • assistance in obtaining excise authorisations: tax warehouse registered consignee, registered consignor, exit permit, intermediary,
    • conducting excise audits,
    • assistance in solving problems with excise goods taxation,
    • indicating the conditions and possibilities of applying excise tax exemptions and preferential, tax rates,
    • adaptating or preparing documentation for excise purposes: excise records, declarations and records,
    • assistance in obtaining exemption from the obligation to provide excise security,
    • assistance in obtaining decisions on loss and wear standards,
    • we also indicate solutions concerning the movement of excise goods: excise duty suspension procedures, the movement of excise goods subject to zero excise duty or exempted from excise duty due to their intended use.
  2. Legislation and lobbying
    Legislation and lobbying

    We support businesses and business organisations at every stage of legislative work. In particular:

    • we prepare drafts of legal acts or specific provisions, together with their justification,
    • we monitor, analyse and evaluate proposals for changes in tax regulations in terms of their impact on the activity of a given company or industry,
    • we prepare comments on draft Polish and European Union tax regulations,
    • we support companies or industries in their contacts with public authorities.
  3. Special Economic Zones (SEZ)
    Special Economic Zones (SEZ)

    We have experience in tax advisory services for companies in the process of investing and conducting business in SEZ.
    In particular we help companies with the following:

    • investment analysis in terms of the possibility of obtaining exemptions from income tax and property tax,
    • tax aspects of conducting business activity by a given company within and outside the SEZ,
    • tax issues related to the provision of production tools (tooling) to a business operating in a SEZ,
    • determining the scope of costs and revenues that may be included in the zone's operations in accordance with the permit to operate in the SEZ.

    We have advised, for instance, one of the largest automotive companies in determining the parameters of an investment in a SEZ.

  4. Municipal and public sector taxes/ local authorities (AD)
    Municipal and public sector taxes/ local authorities (AD)

    Our team provides services related to the effective settlement of VAT by municipalities and their units and municipal companies.
    Our assistance includes such things as:

    • handling the process of recovering VAT amounts not recovered in previous years,
    • consultancy on municipal investments.
  5. Tax advice for employees and employers
    Tax advice for employees and employers

    Our experts advise on labour issues related to, among others:

    • taxation of income from work obtained in Poland and abroad,
    • selection of tax-optimal forms of employment and remuneration,
    • delegating managerial staff to work abroad, and to Poland,
    • the scope of duties and responsibilities of the payer of personal income tax and social security contributions,
    • a review of the employer's personal income tax and social security obligations,
    • establishing social and health insurance obligations, in view of EU legal solutions,
    • tax settlement in Poland of Polish and foreign tax residents due to income earned from work, managerial contracts, contracts for work, contracts for specific work, contracts of mandate,

    Polish and foreign money capital, disposal of real estate, lease, pensions and disability pensions from abroad and other sources of income.
    Among other clients, we have advised a large company from the US on the optimal form of employment of several dozen employees in Poland.

  6. Succession planning, family businesses, wealth management, change of tax residence
    Succession planning, family businesses, wealth management, change of tax residence

    We provide comprehensive support to small and large family businesses and their owners, thanks to our close cooperation with Polish and foreign law firms, investment funds and investors, with companies providing advice on entering foreign markets with goods and services.
    Our experts advise, among other things, on:

    • international tax planning,
    • change of tax residency,
    • tax-efficient structuring of the activity conducted in Poland,
    • ensuring the tax efficiency of business activity,
    • property protection,
    • the generational succession of a business enterprise,
    • taxation of income from investments in monetary capitals, including Polish and foreign capitalfunds, derivatives and alternative investments,
    • taxation of income from the sale or lease of real estate,
    • the tax aspects of the acquisition or transfer of personal property, including inherited or donated property, the division or disposal of common property,
    • tax settlement in the area of inheritance and donation tax, and the choice of optimal jurisdiction and change of tax residence.

    We also offer support in setting up a private foundation. This will make it possible to secure assets and their succession in a comprehensive way, leaving them in the hands of families for generations –
    in the case of unforeseeable events.

  7. Real property tax
    Real property tax

    In particular, we offer comprehensive assistance in the settlement of real estate tax, including:

    • support in the qualification of individual assets for taxation purposes,
    • we carry out effective tax reviews to identify areas of savings,
    • we implement optimisations of tax settlements.
    • we enter into negotiations with local tax authorities and handle any disputes,
    • we advise on the possibilities of optimising the taxation of structures (e.g. using the process of reclassifying structures, separating construction and non-structural parts) and buildings (exclusion from taxation of certain objects remaining within buildings, area measurements, the application of exemptions and tax exemptions, the taxation of complex objects and construction parts of technical equipment, or objects not raised with the use of construction products).
  8. Construction, real estate and infrastructure
    Construction, real estate and infrastructure

    We advise entities operating on the real estate market. We provide services to developers, investment funds, leasing companies and private investors – Polish and foreign.
    Our team comprises specialists with over twenty years of experience in areas including:

    • taxation of income from real estate investments,
    • adjusting the process of providing construction services to changes in the provisions of the VAT Act and the Ministry of Finance's interpretation,
    • taxation of real estate turnover with VAT and civil-law transaction tax,
    • selection of the optimum ownership structure for investments on the real estate market in terms of tax efficiency, taking into account the specific nature of investments in non- residential and residential properties,
    • taxation of alternative forms of investment finance,
    • optimisation of tax depreciation,
    • taxation of leasing and rental of real estate,
    • settlement of expenditures and operating costs of real estate,
    • real property tax.

    We also provide services related to VAT applicable to a company during the construction process. We can adjust the process of providing construction services to changes in VAT in a way that ensures the tax security of transactions. As part of this service, we will design new document templates(attachments to invoices), write procedures for the main contractor and subcontractors, submit applications for appropriate individual tax interpretations and classification opinions, and propose changes in the IT system.

  9. Tax planning and business restructuring
    Tax planning and business restructuring

    Tax planning and restructuring transactions typically involve a number of complex financial and legal issues, in particular tax issues, the effective management of which is key to the success of the transaction. Our experienced team will provide comprehensive assistance in setting up the structureof the business, mergers, acquisitions and the restructuring of companies, as well as any other aspects of tax planning.
    Our services include in particular:

    • support in the sale/purchase of an enterprise or its part, including a due diligence audit,
    • support in the disposal or acquisition of a block of shares;
    • support for mergers, divisions, acquisitions or transformations of economic operators;
    • support for investors in the process of purchasing companies within the framework of restructuring projects,
    • advice on the taxation of management staff in connection with an investment,
    • tax structuring of transactions, creating tax-efficient, safe structures prior to closing transactions,
    • preparation and negotiation of transaction documentation,
    • post-transaction tax assistance.
  10. Duty

    We help businesses entering into transactions with third parties to meet all the requirements of EU customs regulations. We check whether the company applies the proper methodology of customs and tax settlements, identifying possible irregularities and proposing improvements. We support clients in the application of economic and special customs procedures, or can prepare the documentation ourselves. We provide assistance during inspections and proceedings before customs and tax authorities and in court and administrative proceedings.
    Our services include in particular:

    • assistance in planning transactions involving trade in goods with countries outside the EU, in terms of customs and tax costs and the application of non-economic restrictions such as:trade in strategic goods, hazardous goods, etc.,
    • support with the use of economic customs procedures: customs warehousing, inward processing, processing under customs control, temporary admission and outward processing,
    • support in the process of obtaining and applying special customs procedures and simplified procedures,
    • preparing for or assisting in obtaining AEO status,
    • support in tracing the origin of goods and requesting Binding Origin Information,
    • assessing the correctness of the applied tariff classification of goods and applying for BindingTariff Information,
    • representing clients in disputes both at the level of proceedings before the authorities and before the Provincial Administrative Courts and the Supreme Administrative Court.
  11. Tax audits
    Tax audits

    We verify whether businesses correctly fulfil their tax settlement obligations. We check whether they apply the proper settlement methodology, identifying possible irregularities and proposing improvements. We identify areas of potential tax risk and, as a result, we help to correct errors and omissions.
    A tax audit can cover selected titles of budget liabilities (PIT, CIT, VAT, real estate tax), areas of activity (sales and purchases, investments, transfer prices) or specific economic operations or events.
    The final result of a tax audit is a report containing a diagnosis of irregularities and areas giving rise to tax risks. In the report, we indicate the identified omissions and the ways in which they can be corrected, as well as the areas in which improvements can be applied.
    We conduct tax audits for potential investors, entities planning to sell their business, as well as typically internal audits aimed at diagnosing areas of tax risk.
    We have conducted tax audits for companeis operating in the following sectors: automotive, pharmaceutical, financial services, construction, energy.

  12. Fiscal criminal liability
    Fiscal criminal liability

    As experienced lawyers, we specialise in defending individuals responsible for tax settlements (members of management boards, financial directors and chief accountants).
    We conduct audits with respect to fiscal criminal liability. We design and implement measures to limit the tax liability of the individuals managing the company. We can defend our clients in pre-trial proceedings and in court.

    We provide professional help for suspects, defendants and those who have been convicted. We are prepared to take the dispute as far as it needs to go: appeal, cassations and further complaints. We develop procedures to minimise the risk of liability under the Fiscal Criminal Code and to enable the practical use of conciliation institutions provided for in the Fiscal Criminal Code (including active grievances, voluntary admission of liability, effective correction of tax returns, etc.).

    We also provide specialist training dedicated to the individuals responsible for tax settlements, where the aim is to familiarise them with the principles of criminal and fiscal liability and the procedures that help minimise such liability.
    We can help you with any questions you may have:

    • representation at the stage of tax and customs and fiscal audit,
    • defence in the pre-trial phase against financial and non-financial investigative bodies,
    •  defence in court proceedings,
    • preparing all pleadings in the field of fiscal criminal law.
  13. Tax disputes, administrative enforcement
    Tax disputes, administrative enforcement

    Zimny Tax Advisers offers professional assistance in the efficient and effective use of all available legal means to protect the interests of our clients in disputes with tax authorities.

    We offer assistance:

    • in the event that the authority undertakes verification activities during a tax audit, a customs and fiscal inspection and proceedings in tax and customs matters,
    • in enforcement proceedings, providing professional assistance aimed at eliminating or reducing the adverse effects related to administrative enforcement,
    • representing clients in proceedings before administrative courts, including the Supreme Administrative Court,
    • professionally preparing applications for tax interpretations and representing clients before the Minister of Finance and administrative courts within the framework of interpretation proceedings,
    • preparing complaints to the European Commission and participating on behalf of taxpayers in proceedings before the Court of Justice of the EU,
    • professional assistance in how best to challenge unfavourable positions taken by authorities,

    We have successfully supported our clients in complex cases of VAT fraud and in ongoing
    administrative enforcement proceedings, among other things.

  14. Transfer pricing
    Transfer pricing

    We develop a comprehensive transfer pricing policy in the company. We prepare a full range of transfer pricing documentation, including benchmarking. We help companies entering into transactions with related entities to meet all the requirements of the transfer pricing regulations.
    Our services are always tailored to the individual needs of our clients, often resulting from the uniqueness of their business. We strive to eliminate risks arising from improperly conducted transfer pricing policies.
    We provide our clients with support in controlling intra-group transactions and creating documentation. We help to plan and implement new internal transfer pricing policies.

    We provide assistance during inspections by tax authorities and in the event of disputes with authorities and in court-administrative proceedings.
    We prepare a full range of transfer pricing documentation, including benchmarks. We help companies
    entering into transactions with related entities to meet all the requirements of the transfer pricing regulations.
    Our services are always tailored to the individual needs of our clients, often resulting from the uniqueness of their business. We strive to eliminate risks arising from improperly conducted transfer
    pricing policies.
    Our transfer pricing services include the following activities:

    • drafting transfer pricing documentation,
    • preparing comparative analyses in order to establish or verify prices in a transaction with a related party (benchmark),
    • conducting proceedings on price agreements with tax authorities,
    • supporting the taxpayer in the event of tax / fiscal inspections,
    • conducting transfer pricing training,
    • planning, implementing, reviewing and other transfer pricing activities,
    • audit on transfer prices,
    • identifying and reviewing transactions between related parties and assessing the potential risks,
    • analysing the transaction pricing policy currently applied in the group and preparing transfer pricing documentation based on local regulations,
    • advising on appropriate methods of estimating transaction prices in transactions between related parties,
    • preparing documentation supporting the applied transfer pricing method,
    • representing the client during the tax audit, drafting appropriate documentation supporting the taxpayer's position and defending the transaction prices within an inspection carried out by the tax authorities,
    • ongoing support for the implementation of transaction pricing strategies and regular updating of supporting documentation.



ZIMNY Tax Advisers is made up of a group of experienced lawyers dealing with tax law. We gained our experience working in international law firms and in the "big four” firms, advising leading Polish and foreign companies.
We have participated in the largest and most complex transactions on the Polish market. We strive to provide simple and understandable advice that points to specific solutions, and our priority is to maintain an appropriate relationship between the value of the service and its price. We always try to understand the business of our clients, the objectives of a particular organisation and the people working there, so that our advice and solutions are practical and tailored to the business needs of our clients. Our extensive knowledge and many years of experience, also in other areas of law, allow us to look at every problem comprehensively, providing our clients with legal and financial security.



Marcin Zimny
Marcin Zimny

Managing Partner | Tax Adviser | marcin.zimny@zimny.eu

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dr Bartłomiej Korniluk LL.M.
dr Bartłomiej Korniluk LL.M.

Of counsel Prawnik

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Andrzej Andrusiuk
Andrzej Andrusiuk

Of counsel | Doradca podatkowy

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Arkadiusz Duda
Arkadiusz Duda
Tax Adviser| Of Counsel
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Małgorzata Kamińska
Małgorzata Kamińska

Senior Associate Prawnik

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Artur Chamot
Artur Chamot
Senior associate
Doradca Podatkowy Radca Prawny
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Aneta Kamola
Aneta Kamola
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Monika Wołczyńska
Monika Wołczyńska
Statutory Auditor
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Konrad Sałuda
Konrad Sałuda

Attorney-at-law | Of Counsel

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Aleksandra Gwiazda
Aleksandra Gwiazda

Marketing Manager aleksandra.gwiazda@zimny.eu

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In order to provide our Clients with comprehensive service and legal security, we have
established cooperation with:

  • Tax offices in Great Britain, Switzerland, the Netherlands, Malta and Cyprus.

  • The best lawyers in Poland dealing with other areas of law (e.g. corporate law, pharmaceutical law,
    real estate law, energy law).

  • Statutory auditors and accountants.