Filing applications for individual tax rulings

An individual tax ruling allows the taxpayer to obtain the tax authorities’ official and binding position on the application of tax law provisions. An individual ruling provides certainty that the tax treatment of a specific transaction or activity complies with regulations. It protects the taxpayer against negative tax consequences arising from incorrect tax treatment, provided that such treatment results from adherence to the position expressed in the ruling. This protection applies only if the taxpayer acts in accordance with the ruling, in particular by executing the transaction consistently with the description included in the application.

Our offer:


Our services include comprehensive support in the process of obtaining an individual tax ruling, including:

  • performing a preliminary analysis of the transaction to assess the rationale for submitting an application;
  • evaluating the likelihood of obtaining a favourable ruling;
  • providing recommendation for changes to transaction documentation to improve the chance of a positive outcome;
  • preparing the application for an individual tax ruling;
  • filing the application with the competent authority on behalf of clients or supporting the submission process;
  • preparing responses to requests from tax authorities to supplement the factual description of the planned transaction;
  • where necessary, providing support in disputes before administrative courts related to individual tax rulings.
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Maciej Grochulski

Tax advisor and expert in tax proceedings and disputes with tax authorities. Author of numerous articles in professional journals.