Are you considering changes to your corporate structure? We will review your existing structures for tax efficiency and legal compliance.
Planning a contribution in kind, transformation, merger, or division of a company? We will design tailored tax concepts for these transactions.
Do you need support with a company liquidation? We will guide you through the process while minimizing tax burdens.
Do you earn income abroad or have you sold assets? We will help you settle your taxes and support your accountant.
Are you unsure whether you are paying taxes correctly? We will review your situation and help you correct any potential errors.
Have you received an inheritance or a gift? We will assist you in declaring it properly and handling the tax settlement.
Is your Polish company paying dividends, interest, or IP royalties? We will advise you on how to avoid withholding tax and prepare the necessary applications.
Do you have a foreign company, foundation, or fund? We will explain the tax implications and guide you on how to address potential issues.
Do you need an audit of a foreign company? We will prepare a comprehensive defence file to demonstrate the beneficial owner of the income.
Are you considering changing your tax residency? We will explain the implications of relocating to another country.
Do you need help planning the change? We will guide you through the process step by step.
Do you want to be sure everything is fully compliant? We will coordinate the residency change process both in Poland and in the country you are moving to.
The founder of a Polish technology company approached us for support in planning the family succession process. The main objective was to separate asset ownership from financial benefits while securing the family wealth and preparing the company for transfer to the next generation.
We implemented a new ownership structure in which a family foundation in Liechtenstein serves as a protective vehicle for the client’s assets. We carried out a cross-border merger of the client’s Polish company with a new holding company in Liechtenstein. A key aspect of the project was negotiating the foundation’s governing documents with a venture capital fund, a significant investor in the client’s company. In addition, we addressed the client’s relocation plans to Switzerland by analyzing the legal and tax implications under Swiss law.
A Polish owner of an international business approached us to adjust the holding structure to the new business reality. Business expansion and the establishment of a family foundation required optimizing financial flows and diversifying geographical risks related to the war in Ukraine.
We conducted a comprehensive analysis of cash flows within the group and assessed the role of individual functions in its structure. Based on this analysis, we implemented significant changes, including the relocation of certain group entities and a cross-border merger of the Polish holding company with a Czech entity. As a result, the main management company and the holding company were transferred to the Czech Republic, reducing geographical risks.
The KORDIA Legal team provides ongoing advisory and support to a wealthy Polish family on various matters concerning their global holding structure. Our work includes managing a family foundation in Liechtenstein and overseeing group reorganizations across multiple jurisdictions. The client engaged us to assist with a partial exit from one of their portfolio companies, in a transaction valued at USD 100 million. The project also involved designing a reinvestment scheme post-transaction, taking into account structures in Liechtenstein, the Netherlands, and Luxembourg.
We implemented a pre-transaction structure using a Dutch partnership and then designed a reinvestment framework spanning several jurisdictions, including Liechtenstein, the Netherlands, and Luxembourg. In addition, we developed and secured financing structures for the client’s Polish investments, utilizing capital from Swiss banks secured against the client’s global assets.
We provided comprehensive support in setting up a testamentary trust in the British Virgin Islands (BVI), based on the provisions of a Luxembourg will. The key beneficiary of the trust was the settlor’s wife, a Polish tax resident. The purpose of the project was to assess potential tax liabilities arising from the creation and operation of the trust.
We conducted a detailed analysis of the tax consequences related to the activation of the trust upon the settlor’s death, including the taxation of the trust’s income and the distribution of funds to the beneficiary. The project also covered the potential classification of the trust as a Controlled Foreign Corporation (CFC) and an assessment of inheritance and gift tax (IHT) and personal income tax (PIT) implications. In addition, we examined the tax consequences of transferring donations from the trust to a Cypriot charitable foundation.
The founder of a publicly listed capital group engaged us to establish a family trust in Liechtenstein to hold the majority of the family’s wealth. The trust’s purpose was to protect against the dilution of ownership in the group, preserve family capital, and facilitate succession planning.
We established the trust in Liechtenstein and obtained a groundbreaking tax ruling confirming that the trust itself was not subject to taxation, with income taxable only at the settlor’s level. As a result, distributions from the trust were deemed tax neutral. This was the first such ruling in Poland.
A transport company asked us to assist with an asset reorganization. The aim was to secure key assets and establish a new entity capable of providing public transport services, while at the same time limiting the impact of conflicts between shareholders.
We analyzed possible reorganization scenarios, including sale, contribution in kind, and company division. We recommended selling the assets to a new company and leasing them back. We also proposed solutions to minimize tax risks, including the potential application of a reduced CIT rate (9%) and the Estonian CIT regime.
The owner of a Polish home appliance company asked us to help reorganize the ownership structure of his luxury vessel (26 meters long), anchored in the Adriatic, in preparation for its planned sale. In addition, the client requested the design of an optimal structure for the purchase of a new yacht from a Polish shipyard, with secured bank financing.
We designed a Malta-based holding structure for both the existing and the new yacht, both of which are registered in Malta. We secured financing for the new vessel by establishing a mortgage on it, in line with the requirements of the loan agreement.
The co-owner of an international company asked us to assist in planning his relocation from Poland to Switzerland. The client had previously received shares in the company as a gift from his father. The key challenge was to minimize exit taxes related to leaving Poland, which could have amounted to as much as 19%.
We carried out precise pre-move tax planning and obtained a groundbreaking tax ruling under which the client, upon changing residency, would be subject to a 3% exit tax on unrealized gains instead of 19%. This was the first case in which the reduced tax rate was approved.
Do you need professional legal advice? Our team of experienced lawyers is ready to provide you with support and expertise in any situation. We believe that every matter deserves an individual approach and the highest standard of legal service.
office@kordialegal.pl
