Responsible Partner
Marcin Frank
Partner
Co-founder of Zwyrtek Group. Specialises in M&A transactions, succession, family foundations and advisory for private and family businesses.
Full profileAdvisory
Tax advisory.
Effective tax management today requires more than correct returns. We support companies with ongoing compliance, disputes, transactions, reporting, transfer pricing, tax technology and environmental obligations.
Our tax advisory combines the Tax & Legal practice with Zwyrtek Group's experience of working with owners, boards and finance directors.
What we do
Scope of work.
CIT and corporate income tax
Ongoing advisory, tax opinions, planning of CIT and withholding tax exposure, and the tax consequences of business decisions.
VAT, excise duty and indirect taxes
Domestic and cross-border transactions, KSeF (the Polish National e-Invoicing System), return corrections, excise duty and risks in the trading of goods.
Transfer pricing
TPR documentation, master file and local file, benchmarking studies, group policies and support in dealings with related parties.
MDR and tax reporting
Identification of reportable tax schemes, MDR filings, internal procedures and support with reporting obligations.
Tax disputes and proceedings
Representation before tax authorities and administrative courts, preparation of arguments and defence of the client's position.
Tax aspects of M&A transactions
Tax due diligence, transaction structuring, reorganisations, post-deal integration and identification of tax risk.
Tax technology and processes
Support with KSeF, reporting automation, organising tax data, systems integration and control of tax processes.
Environmental taxes and charges
Identifying and settling obligations relating to environmental, product and packaging charges, waste, emissions and environmental reporting. We also help companies analyse obligations arising from the PPWR (EU Packaging and Packaging Waste Regulation), EPR (extended producer responsibility) and BDO (the Polish waste database register), linking packaging data with records, reporting and environmental settlements.
Full PPWR implementation
Who we work with
Who we work with.
We work on both the day-to-day tax function and projects requiring transactional, technological, regulatory or contentious analysis. The scope of support is tailored to the company's situation, the scale of risk and the board's decision-making model.
Family businesses
Ownership structuring, succession, the Polish family foundation, asset protection and owners' day-to-day tax decisions.
Growing SMEs
Ongoing CIT/VAT support, organising the tax function, group policies and support in scaling the business.
International corporates
Cross-border settlements, transfer pricing, reporting to headquarters, withholding tax, VAT and group-wide risk.
Manufacturing and trading companies
VAT, excise duty, customs, environmental charges, trade in goods, documentation and supply-chain risk.
Ways of working together
How we can work together.
Not every matter needs a large project. Some decisions call for a quick consultation, others for ongoing oversight of the tax function, and others still for a full advisory, transactional or technology project.
Quick consultation
For individual decisions, interpretations or risk verification.
Ongoing Tax & Legal Hotline support
For boards and CFOs who need regular access to experts.
Advisory project
For transactions, disputes, reorganisations, KSeF roll-outs, transfer pricing or tax reviews.
Cooperation model
Ongoing decision support.
Not every decision requires an advisory project. In many situations, what matters most is a quick consultation with an expert who understands the business context and can point to the right course of action.
Executive Tax & Legal Hotline.
Ongoing access to tax and legal advisors on a subscription basis. Support for day-to-day decisions — fast, without formal projects or unpredictable costs.
See how it worksThe tax function
Tax as part of management decisions.
Tax is increasingly rarely confined to compliance alone. It affects pricing, margins, financing, group structure, transactions, relationships with counterparties, technology and reporting. That is why we look at tax from the perspective of management decisions, not just a single return.
We help companies build a tax function that is compliant, cost-predictable and understandable to the people making business decisions.
- compliance and the safety of settlements,
- control of the board's risk and liability,
- data, processes and technology in tax.
Partner responsible for this practice
The Tax & Legal practice is led by partners who combine tax, legal, transactional and ownership perspectives. Our recommendations therefore consider not only the rules, but also their real consequences for management boards, owners and company finances.
Insights
Related analyses and publications.
Tax
New Anti-Bullying Rules in Poland from November 2026: What Employers Need to Implement Now
From 5 November 2026, a formal policy in a drawer is no longer enough. A new definition of workplace bullying, a lower burden of proof, minimum compensation and a duty of systematic prevention — what employers, HR and compliance teams need to implement in Poland.
8 min read
Tax
A business ready for succession. Michał Zwyrtek on AI, digital transformation and generational change
Michał Zwyrtek explains how AI, digital transformation and organisational readiness can support succession in a family-owned business.
8 min read
Tax
From lab to recyclable packaging. Teresa Sermak at InterNanoPoland 2026
Teresa Sermak of Zwyrtek Group spoke at InterNanoPoland 2026 about PPWR, advanced materials and the commercialisation of new technologies.
6 min read
Process
How does the cooperation work?
- 01
Conversation and understanding the situation
- 02
Diagnosis of tax risks and obligations
- 03
Recommendation and scope of work
- 04
Implementation and ongoing advisory
- 05
Representation in disputes, if needed
- 06
Ongoing support and periodic reviews
When
When is it worth talking to us?
- you are planning a transaction, a restructuring or a change of ownership,
- an audit or proceeding requires external, independent representation,
- your VAT, CIT or withholding tax settlements are generating recurring errors or risk of dispute,
- you face new MDR, KSeF, transfer pricing or ESG/CBAM reporting obligations,
- you need a second opinion on a decision with material tax impact,
- your current tax support can no longer keep pace with the scale or structure of the group.
FAQ
Frequently asked questions.
When a planned business decision has a real effect on CIT, VAT or withholding tax settlements, or on the board's liability. These are most often transactions, reorganisations, an investor coming in, succession, KSeF roll-out, transfer pricing, a tax audit, or a change to the group's settlement model. Advisory is also worth bringing in when the existing accounting and tax team needs a second, independent opinion on a matter with significant impact on the company. We support both the ongoing tax function and one-off matters — from a short consultation to a full advisory project run together with our legal and accounting practice.
Yes. We handle domestic and cross-border VAT, excise duty and trade in goods — including the classification of goods, documentation, split payment, chain transactions and intra-EU settlements. We also analyse related customs and logistics risk and the consequences of the distribution model and supply chain. In practice, VAT, excise duty and customs rarely exist in isolation from commercial contracts, group flows and the accounting system — which is why we work in one team with legal advisory and accounting, so that recommendations are consistent on the tax, legal and operational side.
Yes. We prepare local file and master file documentation, the TPR form, benchmarking studies and transfer pricing policies for Polish and international groups, in line with OECD guidelines. We also review the compliance of related-party settlements with the actual business model, support group restructurings, and prepare for TP audits and disputes. In transactional projects and reorganisations we assess the transfer pricing consequences already at the structuring stage, to avoid having to correct documentation after the fact.
Yes. We represent clients in customs and fiscal audits, tax proceedings and administrative court cases before the Regional Administrative Court (WSA) and the Supreme Administrative Court (NSA). We also recommend action before an audit even starts — reviewing risk areas, organising documentation and preparing arguments — which often narrows the scope of any dispute. During proceedings we are responsible for the defence strategy, communication with the authority, drafting pleadings and running the case. Fiscal criminal cases requiring defence counsel are handled separately by an advocate or attorney-at-law with the relevant licence.
Yes. Environmental, product and packaging charges, waste, emissions and environmental reporting combine a regulatory and a tax perspective. We help identify them, settle them correctly and embed them in the company's processes.
Yes. The Executive Tax & Legal Hotline is an ongoing-support model for boards, owners and CFOs — regular access to tax and legal experts, short consultations, a second opinion on day-to-day decisions, and a fast response to situations requiring independent judgement. The client has a dedicated point of contact and an agreed response time, billed monthly. The Hotline does not replace an advisory project for major transactions or reorganisations — it is, however, the right model for companies where decisions with tax impact arise regularly and require a quick response.
Yes. We carry out tax due diligence, transaction structuring, reorganisations, post-deal integration and risk identification — in one team with our M&A and Tax & Legal practice.
Yes. We represent clients in audit, tax and administrative court proceedings before the Regional Administrative Court (WSA) and the Supreme Administrative Court (NSA).
We tailor the fee model to the nature of the engagement. For ongoing support and the Tax & Legal Hotline, we propose a monthly retainer with an agreed scope, response time and hour cap. For projects — transactions, reorganisations, KSeF roll-outs, tax reviews — we use a fixed fee per stage or an hourly model with an estimate. In selected matters, such as recovering overpaid tax, a fee partly based on success fee is possible. We always confirm the scope, timetable and fee model in writing before starting work.
Yes. We support KSeF (the Polish National e-Invoicing System) roll-out from the tax, process and organisational side — from a readiness audit and document-flow mapping, through configuring processes and setting roles and responsibilities, to training accounting and tax teams. We also analyse the impact of KSeF on VAT policy, the flow of purchase and sales invoices, integration with finance and accounting systems, and internal controls. Technical implementation is carried out together with the system provider — our role focuses on the tax, process and compliance layer.
We provide an initial response within 4 business hours; a complete position is delivered within a timeframe agreed for the matter.
Yes. We combine ongoing tax advisory with ownership-side support — succession, the Polish family foundation, group restructuring and preparation for transactions. We work together with our private and family business practice and our M&A practice.
Yes. A client can use Zwyrtek Group's tax advisory and Zwyrtek Business Services' accounting and HR outsourcing within one team — with a single point of contact and a consistent approach to settlements, reporting and tax risk.
Do you need support with a tax matter?
Book a 30-minute call with a partner. No obligation, no fee.