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Catalogue · JTWPOLAND series

Biblioteka Restrukturyzacji

The Restructuring Library: guides for shareholders, management boards, accountants and advisers preparing a reorganisation. The series is currently published in Polish; selected titles are also available in English, German, Chinese and Korean. Each entry shows the scope, the contents, the number of pages, the legal reference date and the language of the edition offered; the request form and the e-mail with the download link are in that language.

Restructuring

JDG → spółka z o.o.

Sole trader to sp. z o.o.: procedure, taxes and first settlements

A guide to converting an entrepreneur who is a natural person into a single-shareholder sp. z o.o.: choosing the route against a contribution in kind or a sale of the business, documents and the procedure step by step, closing the entrepreneur’s PIT settlements, the company’s first CIT and VAT settlements, profits earned before the conversion, and the books of account. The publication closes with four tools, each with a printable form and a completed example: a list of documents and working method, a working timetable, a schedule of values and tax history, and questions for closing the project. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 69
Size: 1.0 MiB
Language: English
Edition: 1.1
Legal position as at: 17 September 2026
Series no.: E01

Contents

Deciding to change the form of business
The entrepreneur, the company and the management board: a map of liability
Documents and data before the procedure begins
The conversion procedure step by step
Closing the entrepreneur’s PIT settlements
CIT of the converted company
Profits earned before the conversion
VAT, tax identification number (NIP), invoices and systems
Books of account, transitional settlements and the first closing
Timetable, examples and the closing check
Tools: list of documents, working timetable, schedule of values, questions for closing the project

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Translation of the Polish edition; in the event of any discrepancy between the two versions, the Polish version prevails. The request form and the e-mail are in English. Also available in: Polski · Deutsch · 中文 · 한국어

Restructuring

Przekształcenia spółek w praktyce

Transformation of companies in practice: choice of legal form, taxes and settlements with shareholders

Transforming a company from the choice of direction to the first settlements in the new form: legal form and taxpayer status, the two routes for transforming a civil-law partnership (spółka cywilna), transforming a partnership into another partnership or into a capital company and transforming a capital company into another form, followed by the shareholders’ settlements (historical profits, current distributions and the tax cost of shares and rights), PCC and VAT as two separate tests, and the books, notifications and the move to the new form. Three transformation projects: from data to decision. The publication closes with three tools, each with a printable form and a completed example: a table of transformation directions and tax status, a register of historical profits, and a checklist for the standard and the simplified procedure. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 91
Size: 1.5 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E02

Contents (chapter titles translated from the Polish)

How to choose the direction of transformation
Legal form and taxpayer status
Civil-law partnership (spółka cywilna): two separate transformation routes
A partnership into another partnership
From a partnership to a capital company
From a capital company to another form
Shareholders: historical profits, current distributions and the tax cost of shares and rights
PCC and VAT: two separate tests of the transformation
Books, notifications and the move to the new form
Three transformation projects: from data to decision
Tools: table of transformation directions and tax status, register of historical profits, checklist for the standard and the simplified procedure

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

Połączenie spółek krok po kroku

Merger of companies step by step: procedure, tax neutrality and settlements

A domestic merger of companies from the decision to the first settlements after registration: the purpose, direction and limits of the merger, the variants and the applicable simplifications, the procedure from the merger plan to registration and succession (what passes and what requires action), followed by three CIT tests for the companies, the shareholders, losses and special CIT regimes, VAT, PCC and settlements at the turn of periods, the books of account, financial statements and the tax bridge of values, and the economic rationale, MDR and transfer pricing. Four mergers in practice and a summary of the conditions for closing the project. The publication closes with three tools with printable forms and examples: the merger timetable and documents, a neutrality test for the companies and the shareholders, and the merger date and the first settlements. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 60
Size: 1.1 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E03

Contents (chapter titles translated from the Polish)

The merger decision: purpose, direction and limits
Merger variants and the applicable simplifications
The procedure: from the plan to registration
Succession: what passes and what requires action
CIT of the companies: three tests instead of a single declaration of neutrality
Shareholders, losses and special CIT regimes
VAT, PCC and settlements at the turn of periods
Books of account, financial statements and the tax bridge of values
Economic rationale, MDR and transfer pricing
Four mergers in practice
Summary: conditions for closing the project
Tools: merger timetable and documents, neutrality test for the companies and the shareholders, merger date and the first settlements

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

Podział spółki: wydzielenie czy wyodrębnienie?

Division of a company: partial division or division by separation? Procedure, taxes and documentation

A comparison of the two forms of division in which the company being divided continues to exist — a partial division and a division by separation — from the purpose and the ownership structure, through the two organised parts of an enterprise, the division plan and the procedure, to CIT of the company being divided and of its shareholders, VAT, real estate and PCC, tax succession, the books of account and the steps after registration. The publication closes with three tools, each with a printable form and a completed example: a variant-selection sheet, two ZCP descriptions in place of a single statement and a register of transitional items. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 76
Size: 1.1 MiB
Language: English
Edition: 1.1
Legal position as at: 17 September 2026
Series no.: E04

Contents

The purpose of the division and the choice of variant
The ownership structure before and after the division
Two organised parts of an enterprise
The division plan and the corporate procedure
CIT on the part of the company being divided
The company receiving the assets and the shareholders
VAT, real estate and PCC
Tax succession and transitional settlements
Books of account, financing and steps after registration
Cases and an implementation timetable
Tools: variant-selection sheet, two ZCP descriptions, register of transitional items

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Restructuring

Aport do spółki

Contribution in kind to a company: an enterprise, an organised part of an enterprise (ZCP), real estate and other assets

Contributing an enterprise, an organised part of an enterprise (ZCP), real estate, intellectual property rights or other assets to a sp. z o.o.: the contribution in kind and its alternatives, what is actually contributed, the contributor, the recipient and the capital structure, and the steps needed for an effective contribution, followed by income tax for the contributor, the consequences for the company receiving the contribution, VAT (the object, the consideration and the history of deductions), PCC and the limits of the exclusion from taxation, and the effective transfer and obligations after the contribution. Four cases, an implementation timetable and a complete set of documents. The publication closes with three tools, each with a printable form and a completed example: a contribution questionnaire, a statement of values and share premium (agio), and a list of consents and steps for an effective transfer. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 85
Size: 1.5 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E05

Contents (chapter titles translated from the Polish)

Contribution in kind and its alternatives
What is actually contributed
The contributor, the recipient and the capital structure
How to make the contribution effective
Income tax for the contributor
Consequences for the company receiving the contribution
VAT: the object, the consideration and the history of deductions
PCC: what is taxable and when the exclusion applies
Effective transfer and obligations after the contribution
Four cases and implementing the contribution
Tools: contribution questionnaire, statement of values and share premium (agio), list of consents and steps for an effective transfer

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

Wymiana udziałów i budowa holdingu

Exchange of shares and building a holding structure: conditions, taxes and documentation

Contributing shares to a holding company and building an ownership structure from the Polish tax and corporate perspective: the holding as a business objective and its alternatives, the map of voting rights, the exchange-of-shares test, the history of the shares and the tax value of the stake, and domestic law against Directive 2009/133/EC and the limits of the dispute, followed by the tax consequences for each participant, the cost and tax on a later exit, dividends, the Polish holding company (PSH), withholding tax and the real functions of the holding, and economics, MDR, transfer pricing and financing. Three cases and the sequence of transactions. The publication closes with three tools, each with a printable form and a completed example: a table of the history of shares and voting rights, a checklist of tax preferences for each participant, and a memo on the purpose and real functions of the holding. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 92
Size: 1.5 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E06

Contents (chapter titles translated from the Polish)

The holding as an objective: the business need and the alternatives
Map of voting rights: entities, stakes and successive acquisitions
The exchange-of-shares test
The history of the shares and the tax value of the stake
Domestic law, the Directive and the limits of the dispute
Tax consequences for each participant
Cost and tax on a later exit
Dividends, PSH, WHT and the real functions of the holding
Economics, MDR, transfer pricing and financing
Three cases, the sequence of transactions and tools
Tools: table of the history of shares and voting rights, checklist of tax preferences for each participant, memo on the purpose and real functions of the holding

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

Sprzedaż firmy: udziały czy przedsiębiorstwo?

Selling a business: shares or the enterprise? Taxes and preparing the transaction

Selling a business in two models – the shares (share deal) or the enterprise, an organised part of an enterprise (ZCP) or assets (asset deal): what is being sold, the parties’ objectives, preparing the transaction (documents, due diligence, data and a list of gaps), the tax consequences of a share deal and an asset deal, real estate and VAT, and the buyer’s liability, followed by the price and settlements (allocation, locked box, completion accounts, contingent payments) and closing and handover. A comparison of both models of the same transaction in figures. The publication closes with three tools, each with a printable form and a completed example: a list of documents for due diligence and certificates, a table comparing an asset deal and a share deal, and a record of data and settlements for handover. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 74
Size: 1.0 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E07

Contents (chapter titles translated from the Polish)

What is being sold: shares, an enterprise, an organised part of an enterprise (ZCP) and assets
The parties’ objectives: price, financing, takeover of contracts and the history of risks
Preparing the transaction: documents, DD, data and a list of gaps
Share deal: the seller’s PIT/CIT, the cost of the shares, PCC and VAT
Asset deal: revenue, costs, ZCP and the buyer’s tax values
Real estate and VAT: enterprise/ZCP, exemption, taxation and adjustments
The buyer’s liability: certificates, tax arrears and the limits of contractual protection
Price and settlements: allocation, locked box, completion accounts and contingent payments
Closing and handover: documents, books, employees and consents
A comparison in figures: two models of the same transaction
Tools: list of documents for due diligence and certificates, table comparing an asset deal and a share deal, record of data and settlements for handover

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

Finansowanie spółki przez wspólników

Financing a company by its shareholders: additional contributions (dopłaty), loans, debt conversion and debt forgiveness

Choosing how the shareholders finance a sp. z o.o. and settling an existing debt owed to a shareholder: diagnosing the financing need, additional contributions (dopłaty) and capital, the shareholder loan (terms, interest and documents), debt conversion, and debt forgiveness and recovery options, followed by financing costs (from accrual to deduction), VAT and PCC, transfer pricing and WHT, and the books and documentation of a single financing history. Three numerical cases and a procedure for choosing the solution. The publication closes with short tool cards for use in the company and three tools, each with a printable form and a completed example: a financing choice table, a register of capital, interest and the method of settlement, and a TP / WHT / PCC checklist. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 74
Size: 1.3 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E08

Contents (chapter titles translated from the Polish)

The problem first, then the instrument
Additional contributions and capital: owners’ money
The shareholder loan: terms, interest and documents
Debt conversion: what is a contribution and what is a payment
Debt forgiveness and recovery options
Financing costs: from accrual to deduction
VAT and PCC: two separate determinations
Transfer pricing and WHT: independent sets of obligations
Books and documentation: a single financing history
Three cases and choosing the solution
Tools for use in the company: short versions of D01–D03
Tools: financing choice table; register of capital, interest and the method of settlement; TP / WHT / PCC checklist

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

Likwidacja spółki i wydanie majątku wspólnikom

Liquidation of a company and distribution of its assets to the shareholders: taxes and final obligations

Winding up a sp. z o.o. taxed under the standard CIT regime: ways of ending the company’s activity, the liquidation plan and the liquidators’ tasks, creditors, liabilities and the assets available for distribution, the sale of assets before distribution and the distribution of assets and rights to the shareholders instead of cash, followed by the consequences for the shareholder (PIT, CIT and the limits of exemptions), winding up a tax-transparent partnership, VAT and PCC, and the books of account, tax returns and archive. Three cases and basic versions of the closing tools. The publication closes with three tools, each with a printable form and a completed example: a list of liquidation stages, a table of the company’s and the shareholders’ taxes, and a record of settlements and archiving. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 74
Size: 1.3 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E09

Contents (chapter titles translated from the Polish)

Ways of ending the company’s activity
The liquidation plan and the liquidators’ tasks
Creditors, liabilities and the assets available for distribution
Selling the assets before distribution
Distributing assets and rights instead of cash
The shareholder: PIT, CIT and the limits of exemptions
Winding up a tax-transparent partnership
VAT and PCC: a separate classification of each event
Books of account, tax returns and the archive: several different end dates
Three cases and closing tools
Tools: list of liquidation stages, table of the company’s and the shareholders’ taxes, record of settlements and archiving

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

Czy to jest ZCP?

Is it an organised part of an enterprise (ZCP)? The classification test, documents and tax consequences

The test for classifying an organised part of an enterprise: organisational, financial and functional separation, components not transferred, the moment of assessment and the evidence file, followed by ZCP in a division of a company, in a contribution in kind and a sale, and in commercial real estate. Six cases with an outcome and the opposite variant. The publication closes with three tools, each with a printable form and a completed example: a ZCP questionnaire, a register of evidence and a classification memorandum. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 80
Size: 1.1 MiB
Language: English
Edition: 1.1
Legal position as at: 17 September 2026
Series no.: E10

Contents

An enterprise, an organised part of an enterprise (ZCP) and a set of assets
Organisational separation
Financial separation
Functional independence
Components not transferred and dependencies after the transaction
The moment of assessment and the evidence file
ZCP in a division of a company
ZCP in a contribution in kind and in a sale: taxes, values and liability
Commercial real estate: why letting does not settle everything
Six cases: outcome, evidence and the opposite variant
Glossary and final working instructions
Tools: ZCP questionnaire, register of evidence, classification memorandum

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Restructuring

Neutralność podatkowa restrukturyzacji

Tax neutrality of restructurings: conditions, economic rationale and GAAR

Assessing the tax neutrality of mergers, divisions, contributions in kind and exchanges of shares – from identifying the taxpayer and the conditions for the preference to documenting the decision and choosing a protective instrument: what neutrality really means, the participants and the tests for each transaction, tax values and the history of the shares, the specific anti-abuse clauses in CIT and PIT, and GAAR as a separate test of the transaction as a whole, followed by an evidence-based economic rationale, the individual tax ruling and the protective opinion, and MDR and transfer pricing as separate obligations. Three cases – from argument to decision – and an evidence package from preparation to tax audit. The publication closes with three tools, each with a printable form and a completed example: a template economic memorandum, a register of objectives, benefits and evidence, and a sheet for choosing the protective instrument. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 81
Size: 1.2 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E11

Contents (chapter titles translated from the Polish)

What neutrality really means
The participants and the tests for each transaction
Tax values and the history of the shares
Specific anti-abuse clauses in CIT and PIT
GAAR: a separate test of the transaction as a whole
An evidence-based economic rationale
The individual tax ruling and the protective opinion
MDR and transfer pricing: separate obligations
Three cases: from argument to decision
The evidence package from preparation to tax audit
Tools: template economic memorandum; register of objectives, benefits and evidence; sheet for choosing the protective instrument

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

VAT i PCC w restrukturyzacjach

VAT and PCC in restructurings: classifying the transaction and the most common errors

Two separate tests for the same transaction. VAT: from the object of taxation (from assets to a going concern), through real estate and its history and the deduction of input VAT and the history of adjustments, to invoices, succession and transitional settlements. PCC: the transaction, the exclusion and the correct taxpayer, capital, contributions in kind and the limits of the standstill rule, transformations, mergers and divisions, and the tax base, the remitter and the settlement calendar. Three hypothetical transactions: a sale of an organised part of an enterprise (ZCP) with VAT shown incorrectly, a contribution of real estate on the formation of a company and on a share capital increase, and a transformation with historically taxed contributions. The publication closes with three tools, each with a printable form and a completed example: a VAT/PCC classification sheet, a register of the input VAT adjustment history and a table of the taxpayer, the remitter and deadlines. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 81
Size: 1.3 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E12

Contents (chapter titles translated from the Polish)

Two independent tests
The object of VAT: from assets to a going concern
Real estate: history matters more than the label
Deduction of input VAT and the history of adjustments
Invoices, succession and transitional settlements
PCC: the transaction, the exclusion and the correct taxpayer
Capital, contributions in kind and the limits of the standstill rule
Transformations, mergers and divisions
The tax base, the remitter and the settlement calendar
Three transactions, three routes to a correct settlement
Tools: VAT/PCC classification sheet; register of the input VAT adjustment history; table of the taxpayer, the remitter and deadlines

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

Sukcesja podatkowa i rozliczenia po restrukturyzacji

Tax succession and settlements after a restructuring: rights, obligations, invoices and books of account

Assigning a business’s tax history to the correct entity after a merger, a division, a transformation, a contribution in kind or a sale of an enterprise: a map of succession (continuation, succession and liability), transformations of companies and the limited model for a sole trader (JDG), mergers including historical settlements, divisions and the ZCP condition, contributions in kind and sales without automatic universal succession, followed by revenue, costs and losses, VAT and adjustments, tax rulings, decisions and reliefs, books of account, financial statements, the Standard Audit File for Tax (JPK) and taxpayer identification, and the handover record and the review of the first settlements. Three hypothetical cases: a discount after an acquisition, VAT and revenue of a department transferred in a partial division, and an invoice after the conversion of a sole trader (JDG). The publication closes with three tools, each with a printable form and a completed example: a register of open items, a record of the handover of tax data and a timetable of settlements and notifications. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 75
Size: 1.2 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E13

Contents (chapter titles translated from the Polish)

A map of succession: continuation, succession and liability
Transformations of companies and the limited model for a sole trader (JDG)
Mergers: historical settlements as well
Divisions: assets, open items and the ZCP condition
Contribution in kind and sale: no automatic universal succession
Revenue, costs and losses: when and by whom they are recognised
VAT and adjustments: invoices, data, deductions and returns
Tax rulings, decisions and reliefs: what actually continues
Books of account, financial statements, JPK and taxpayer identification
The handover record and the review of the first settlements
Tools: register of open items, record of the handover of tax data, timetable of settlements and notifications

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

MDR przy restrukturyzacjach

Mandatory disclosure rules (MDR) in restructurings: analysis of obligations and transitional provisions

An analysis of MDR obligations in restructurings covering two periods: the rules in force until 30 September 2026 and the changes introduced from 1 October 2026 by the Act of 29 May 2026. The publication discusses the event that triggers the obligation, the participants and their roles, the hallmark test and the cross-border element, divisions, contributions in kind, share exchanges and financing, professional secrecy, MDR deadlines and returns, and the transitional provisions of the amending act. It includes three cases with deadline calculations and three tools: an MDR analysis sheet, a timeline of obligations and a register of decisions and sources.

Author: Zbyszko Pora

Format: PDF
Pages: 63
Size: 1.1 MiB
Language: Polish
Edition: 1.0
Legal position as at: 14 September 2026
Series no.: E14

Contents (chapter titles translated from the Polish)

Dates and the scope of obligations
The arrangement and its participants
The arrangement test: hallmarks, criteria and exclusions
The cross-border element
Typical restructurings
Professional secrecy
Deadlines and returns
The reform and the transitional rules
Documenting decisions
Cases and the final check
Tools: MDR analysis sheet, timeline, register of decisions and sources

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

Ceny transferowe w restrukturyzacjach

Transfer pricing in restructurings: functions, assets, risks and the exit fee

Reorganisation within a group of related entities from the transfer pricing perspective: classifying the event, related-party links and the actual course of the transaction, functions, assets, risks and profit potential, the options realistically available to both parties, the exit fee (when to consider compensation and when not to duplicate it), and the method, forecast and valuation. Next come the local file, the transfer pricing information return (TPR) and deadlines, financing after a change of the business model, and the limits of the transfer pricing analysis in relation to CIT, withholding tax (WHT), VAT and MDR. Three case studies: a full-risk distributor moving to a limited-risk model, a transfer of customer relationships and the sales team, and financing with a genuine change in control over risk. The publication closes with three tools, each with a printable form and a completed example: functions, assets and risks before and after the change, a sheet of the options realistically available, and valuation data with a test of TP obligations. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 69
Size: 1.2 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E15

Contents (chapter titles translated from the Polish)

Business restructuring: first the event, then the label
Related-party links and the actual course of the transaction
Functions, assets, risks and profit potential
Options realistically available: two sides of one decision
Exit fee: when to consider compensation and when not to duplicate it
Method, forecast and valuation: from data to defending the result
Local file, TPR and deadlines: from classification to signature
Financing after a change of the model: capital is not enough
The limits of the TP analysis: CIT, WHT, VAT and MDR
Three case studies and tools for application
Tools: functions, assets and risks before and after the change; sheet of options realistically available; valuation data and test of TP obligations

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Polish-language edition. The request form and the e-mail are in Polish.

Restructuring

Restrukturyzacje transgraniczne

Cross-border restructurings: the Polish legal and tax perspective

A cross-border merger, division or conversion of a company, or a transfer of business activity, involving a Polish taxpayer – the Polish tax consequences, documents and cooperation with a foreign adviser: a map of jurisdictions from the business decision to the applicable law, cross-border procedures (documents, protection of participants and certificates), income tax neutrality separately for the company, the shareholder and the transferred assets, a permanent establishment in Poland and the continuation of settlements, and exit tax, followed by withholding tax and the beneficial owner of payments, tax residence, CFC and financing after the change of structure, MDR and transfer pricing as two separate control systems, and the books of account, currencies and the project timetable. Three projects and a package for cooperation with a foreign adviser. The publication closes with three tools with printable forms: a cross-border restructuring checklist, a package for cooperation with a foreign adviser with a Polish–English list of questions, and a project timetable and document map with control calculations. Sources are cited in footnotes and in the bibliography.

Author: Zbyszko Pora

Format: PDF
Pages: 107
Size: 1.7 MiB
Language: Polish
Edition: 1.0
Legal position as at: 22 September 2026
Series no.: E16

Contents (chapter titles translated from the Polish)

Map of jurisdictions: from the business decision to the applicable law
Cross-border procedures: documents, protection of participants and certificates
Income tax neutrality: the company, the shareholder and the transferred assets separately
A permanent establishment in Poland and the continuation of settlements
Exit tax: loss of Poland’s taxing right
WHT and the beneficial owner of payments
Residence, CFC and financing after the change of structure
MDR and transfer pricing: two separate control systems
Books of account, currencies and the project timetable
Three projects and a package for cooperation with a foreign adviser
Tools: cross-border restructuring checklist, package for cooperation with a foreign adviser, project timetable and document map

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Polish-language edition. The request form and the e-mail are in Polish.

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