Rafał specialises in advising on corporate income tax settlements, particularly as regards tax relief (B+D and IP Box) and lump sum tax on company income
(the so-called Estonian CIT). Rafał helps on projects to reorganise capital groups, due diligence studies, projects to buy or sell commercial real estate, and proceedings before tax authorities. His experience also includes advising on VAT, including having advised financial institutions (banks, leasing companies, payment institutions, capital market institutions) and entities from the FMCG sector.

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Education

  • Master’s degree in Law, University of Warsaw

Languages

  • English

Main areas

Selected projects

  • Advising Baltic Power, a joint venture between ORLEN Group and Northland Power, on the first offshore project finance transaction on the Polish market. The financing obtained by Baltic Power with a total value of over EUR 4.7bn. The advice included negotiating the provisions of loan documentation and hedging contracts based on currency and interest rate derivatives with a consortium of 25 financial institutions
  • Advising Santander, including by preparing a comprehensive tax opinion on the CIT consequences of its trading patterns in Poland and voluntary carbon credits (VCC)
  • Advising a computer game developer on implementing a CIT settlement mechanism under the IP Box, including obtaining individual tax interpretations, supporting tax calculations and submitting tax declarations
  • Advising Bruggen, including by designing internal tax procedures
  • Advising Medinco, including by analysing the possibility to implement the Estonian CIT procedure, providing tax and legal support when transforming the company into a limited liability company and adapting its capital structure to fit the Estonian CIT requirements. Helping to calculate temporary differences and submit declarations
  • Advising Sigma Group, including by developing a strategy for reorganizing the group structure to fit the Estonian CIT requirements. Supporting the transition to the Estonian CIT taxation procedure
  • Advising Spedimex, including by preparing a memorandum on implementing the Estonian CIT, helping to calculate temporary differences and submitting CIT returns. Preparing applications for individual tax interpretations