Transactions with tax havens

Tax advice during transactions with tax havens

As part of the BTLA, we provide a service dedicated to organizations that make transactions with tax havens. Such a transaction takes place when the entity has its place of residence, registered office or management board in one of the countries applying harmful tax competition and is subject to transfer pricing regulations. The list of countries applying harmful price competition is included in the Regulation of the Minister of Finance of March 28, 2019. Pursuant to the amended CIT Act, from 2021, the documentation obligation covers all transactions with a paradise entity with a value exceeding PLN 2,500,000 per year in the case of for a financial transaction and PLN 500,000 for another transaction.

How can BTLA help your organization account for transactions with tax havens?

  • We will prepare transfer pricing documentation, taking into account additional elements that the documentation must contain for transactions carried out with tax havens.
  • We will support you in completing the TP-R form and the statement on the preparation of transfer pricing documentation.
  • We will assist you in filing an active grievance in case of default for previous years.
  • We will support you in a possible audit of the transaction by the tax authorities.

Tax advisor support in settlements with tax havens

Transactions with tax havens are sensitive transactions, which is why it is very important to have a professional advisor, such as BTLA, who will support you in verifying your documentation and reporting obligations. The regulations regarding transactions with tax havens have changed over the past years. It is worth checking whether all obligations have been correctly identified for 2021 and for previous years and immediately fulfill the documentation and reporting obligations.

What makes our tax haven settlement support service different?

  • Efficiency and effective execution – we meet the demanding conditions of our clients related to transactions with tax havens and successfully handle complex cases requiring high competence, providing real assistance to our clients.


  • Comprehensive solutions – we offer comprehensive solutions, from the verification of current transactions to the preparation of documentation for new ones and, above all, we support in possible transaction controls before tax authorities, thus comprehensively solving our clients’ problems.
  • Expertise in the area of transactions with tax havens – the BTLA team consists of tax advisors, advocates and legal advisers as well as multidisciplinary experts who are distinguished by comprehensive experience and in-depth knowledge of business practice in the area of transactions with tax havens, allowing clients to focus on running their business without fear of completing all activities related to transactions with tax havens.


  • Individual approach to the client – we are aware of how sensitive transactions with tax havens are, thanks to our experience we are able to provide effective solutions, take over key tasks and help in the case of pending proceedings.