Tax & Corporate Structuring

We provide comprehensive legal and tax support for foreign investors operating in Poland. We assist in creating secure investment structures, effective tax planning, and efficient management of cross-border transactions. Our advisory combines a strategic business approach with in-depth knowledge of the law.

GJW Gramza i Wspólnicy Attorneys-at-Law Partnership provides strategic legal and tax advisory services to foreign investors, corporate groups, family offices, private equity funds, multinational enterprises, and financial institutions operating in Poland and across the European Union.

Our advisory covers holding structures, capital transactions, and comprehensive tax planning within the framework of Polish corporate and tax law. We design legally robust and fiscally efficient investment structures that allow clients to operate in full compliance with regulatory standards, while ensuring effective asset protection in Poland.

Advanced Tax Planning under Polish Law

Effective tax planning is a fundamental element of successful cross-border investment . Our firm provides tailored tax and legal advisory services designed to optimize fiscal outcomes, reduce legal exposure, and support long-term strategic goals.

Our work includes a detailed analysis of Polish tax regulations, EU directives, and relevant international agreements.

We assist clients with:

structuring financing and planning capital flows in cross-border transactions,
designing and implementing tax-efficient holding structures,
developing strategies and ensuring compliance with CIT, VAT, and WHT,

addressing tax residency, CFC, and transfer pricing matters,
applying double taxation treaties and EU directives,
implementing effective corporate governance and compliance frameworks.

All structures are developed with a focus on legal stability, tax predictability, and compliance with both Polish and international tax regimes.

Corporate Structures and Capital Transactions

We advise on the incorporation and restructuring of companies in Poland to support complex cross-border transactions and the investment strategies of international capital groups. Our lawyers provide comprehensive support throughout the entire lifecycle of corporate structures, including:

establishment of legal entities and SPVs (Start-up Poland),
designing and implementing holding structures,
creating corporate governance frameworks for capital groups,

M&A transactions, joint ventures, and reorganizations,
capital transactions, capital increases, share transfers, and company financing,
drafting and negotiating shareholders’ agreements.

Our legal advice ensures that every transaction is designed to meet regulatory requirements, minimize tax risk, and protect the strategic interests of investors.

Regulatory Compliance and International Tax Transparency

Compliance with Polish and EU tax law, as well as international reporting and disclosure standards, is an integral part of our advisory practice. We help clients navigate a highly regulated tax environment, ensuring that their investment and corporate structures are fully compliant with all applicable legal obligations.

Our compliance advisory includes the practical implementation of mandatory disclosure and automatic information exchange rules, including:

DAC6 — mandatory reporting of cross-border tax arrangements to the Polish tax authorities,
MDR — disclosure obligations for intermediaries and taxpayers,
CRS — automatic exchange of financial account information with foreign tax authorities in accordance with OECD standards,
FATCA — reporting obligations concerning U.S. tax residents under the Foreign Account Tax Compliance Act.

We help clients identify reportable arrangements, assess potential disclosure obligations, and implement appropriate internal governance, record-keeping, and reporting procedures.

A comprehensive compliance strategy enables our clients — including foreign investors, capital groups, and financial institutions — to conduct their business with full confidence that their legal and tax structures comply with both domestic and international reporting requirements.

A Boutique Law Firm for Demanding Corporate Clients

GJW Gramza i Wspólnicy Kancelaria Radców Prawnych Spółka partnerska is a boutique legal and tax advisory firm distinguished by its strategic focus and selective approach to client engagement. We advise a carefully curated portfolio of corporate clients, international investors, and capital groups whose operations require the highest levels of legal sophistication, precision, and strategic insight.

Our practice is deliberately niche — designed to deliver bespoke, high-impact legal solutions rather than standardized services. By working exclusively with clients who value excellence and strategic depth, we provide not only legal advice but also long-term partnership, ensuring that each structure and transaction is legally sound, fiscally optimized, and internationally compliant.

We operate at the intersection of law, tax, and cross-border investment, supporting complex, high-value transactions and helping our clients achieve measurable strategic outcomes in Poland and across the European Union.

We operate at the intersection of law, tax, and cross-border investment , supporting complex, high-value transactions and helping our clients achieve measurable strategic outcomes in Poland and across the European Union.