Arena Tax

Arena Tax is a licensed tax advisory company

We support Polish companies and international entities, among others, in the field of corporate income taxation as well as international taxation.

Our partners are entities from leading business industries, including financial sector and new tech industry. Among them are banks, entities from the broadly understood financial ecosystem,  leasing companies, debt collection companies, insurance firms, entities from digital consumer finance and payments sector, investment fund companies, brokerage houses, fintech and IT companies as well as technology companies. Our experienced team of specialists delivers the most complex projects and assists in transactions for the most demanding customers. Currently we are among the 20 largest tax advisory companies in Poland, according to the daily newspaper Rzeczpospolita. Each year we are recognized as a leading tax advisory company in the global directory World Tax and Transfer Pricing World of the specialized tax publisher  International Tax Review.

Our achievements:

Our services

Our goal is to deliver tax advisory services which bring measurable added value for our Clients

We are proactive – whenever we see a possibility of potential tax savings or recognize risk, we determine together what steps are to be taken. During preparation and implementation of the projects we put particular emphasis to professionalism of our services. Our goal is to provide our services with minimal involvement of our partner’s key resources (e.g. time) in the project. We want to enable you to take care of the business, while we handle taxes and finance questions.

Comprehensive implementation of tax solutions

We manage the project in a comprehensive way: we determine the duration of the project, designate members of a team, who are the most experienced in a given service, determine the budget and essential external resources. If necessary, we choose and engage specialists in a given branch both in Poland and abroad, whom we coordinate on every level of the project. Our experience as well as our approach based on the comprehensive implementation of our solutions allow us to deliver our concepts successfully.

International tax structuring

In some cases it is necessary to work out a new tax structure or to amend an existing one. We have vast experience in the field of Polish and international taxation. On your request we will provide you with safe, comprehensive and effective tax solutions which are in the same time in line with to the business model.

Advisory for groups of related enterprises
We analyze the structure of your company in order to provide support on the common tax issues which groups of related enterprises may encounter, such as:
  • financing,
  • management of the tax aspects of the thin capitalization,
  • regulations regarding foreign controlled companies and other.
Analysis of tax risk in terms of Polish and international taxation
Tax advisors of Arena Tax analyse and recommend on solutions planned or adopted by the enterprise in regard to Polish and international taxation. Moreover, upon customer request we carry out risk assessment analyses of solutions proposed by the Company or by thier advisors in regard to taxes.
Advising connected with the transfer of functions within an enterprise Group
Arena Tax provides support in the field of management of tax risks resulting from the plans of reorganization of  the Group of enterprises. We specialize in both Polish and transboundary reorganizational projects.
Tax reviews, Due diligence

We recommend to our partners a tax review in order to verify the correctness of their tax settlements, indicate any potential irregularities, identify areas of a potential tax risk and opportunities for improvement. The result of our tax review is a  presentation of the best method to manage irregularities and to propose measures designed to manage risk/opportunity.

The tax reviews are also often an opportunity to achieve measurable tax savings, as a result of verification of the tax settlement policy, elimination of errors, and recommendations of more favorable arrangements.

We conduct due diligence reviews – both on behalf of sellers and on behalf of buyers.

Transaction advisory services

The team of Arena Tax offers a comprehensive advisory service on the following transactions:

  • support for investors in the process of acquisition of a company as part of restructuring projects,
  • acquisition of a company or part of a company/branch,
  • sale of a company or sale of a part of the company/branch,
  • mergers and takeovers of business entities,
  • demerger of business entities.

Our services encompass assistance in regard to tax at all phases such as negotiations, through the due diligence process, to the completion of the transaction. On every stage we advise our client with a professional analysis, regardless of which side of the process he/she is.

Transfer pricing

We assist our Clients in making decisions in regard to management of the transfer pricing risk.  Our starting point is the analysis of your business activity. Based on the analysis, our tax advisors identify and define risk areas connected with the established methods and the transfer prices applied. From a comprehensive file of transfer pricing documentation to transfer pricing benchmarks – in each case our qualified team delivers transfer pricing support  for Polish and international groups of related companies. We carry out international projects related to the level of transfer price, securing transfer pricing risk in different jurisdictions.

 

More information on the website: www.transferpricingarenatax.com.

Support during tax and fiscal inspections

The team of lawyers, advocates and tax advisors of Arena Tax provides support during tax or fiscal inspections as well as during appeals before tax authorities and before administrative courts. We represent our partners before tax authorities and the fiscal inspection at any stage and level of the auditing and tax proceedings and court-administrative proceedings.

Ongoing and ad-hoc tax advisory

The tax advisors of Arena Tax provide support on the ground of corporate income tax, value-added tax and other taxes imposed under Polish law, as well as on tax ordinance, penal fiscal procedure and other topics which an enterpreneur may encounter. The services are provided in Polish, English and in other European languages.

Transaction system support (IT)

We are well-experienced in supporting clients operating through IT based transactions systems, which include financial services providers, non-material service providers, brokerage houses, e-commerce companies (B2B and B2C) . We offer our clients, in partnership with our sister firm Antareco, an audit and the set up of the IT systems in order not only to manage tax risk and improve processes, but also to identify savings.

DIGITAL APPS

Kalkulator IP BOX

Kalkulacja potencjału oszczędności przy skorzystaniu z opodatkowania przychodu kwalifikowanego w wysokości 5% stawki CIT.

Stosowanie preferencyjnej stawki odnosi się do dochodu z kwalifikowanych praw własności intelektualnej które będą wytworzone, rozwinięte lub ulepszone w ramach prowadzonej działalności badawczo-rozwojowej.

Team

Professionals with extensive experience in Polish and international tax advisory.

The members of our team are licenced tax advisors, legal advisors and attorneys at law specialised in serving the financial institutions – with work experience in the biggest companies from the financial sector in Poland. Our team of tax advisors consists of 10 Managers, each of whom with many years of experience in Polish and international tax advisory and in preparation and implementation of all kinds of tax projects. Our clients are also supported by experienced tax consultants and tax senior consultants, specialised in legal and tax support for Polish and international institutions.

Michał Musielak

Chairman

Tax Advisor

michal.musielak@arenatax.pl

tel. +48 504 138 118

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Michał Musielak

Chairman

Tax Advisor

michal.musielak@arenatax.pl

tel. +48 504 138 118

Lawyer, finance expert and licensed Tax Advisor (No. 10244) with over 19 years of professional experience in providing tax and legal advice.
Work experience & education

During studies and shortly after (1999-2002) he worked as a lawyer in brokerage office, where he was responsible for the tax services for the office and its clients. From 2002 to 2007 he was involved in tax advisory for the financial institutions in Deloitte and Ernst & Young. While working in Ernst & Young he was assigned to perform a function of main tax controller in one of the American capital group banks. In years 2007-2011 he created and managed the tax department in newly established Polbank EFG. He was responsible for all the tax obligations including tax advisory, accounting and tax reporting competence in the bank with the total balance sheet amounting to 20 billion PLN. In years 2011-2012 he has been a partner at KPT Doradcy Podatkowi. He started working in Arena Tax in June 2012.

He graduated from the UAM in Poznań with a law degree (2002) and from the Wyższa Szkoła Bankowa in Poznań with an accounting and corporate finance degree.

Organizations and awards

In years 2008-2011 he chaired the VAT Group in Polish Bankers Association (ZBP). In years 2009-2011 he was a representative of the Polish Bankers Association (ZBP) in VAT Working Group of the European Banking Federation (EBF) in Brussels. As a representative of the Polish Bankers Association (ZBP) he successfully participated in the negotiations with the Polish Ministry of Finance on the provisions of the Polish VAT Act regarding exemption from VAT for services auxiliary to financial services. During Polish Presidency in the Council of the European Union (July – December 2011) he was an Official Representative of the Polish Bankers Association (ZBP) in the European Bank Federation VAT Group.

As one of the few licensed tax advisors in Poland he received an Honorable Polish Bankers Association Medal (2012).

Languages

Polish, English

Aneta Saramak

CEO

Tax Advisor

aneta.saramak@arenatax.pl

tel. +48 603 700 015

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Aneta Saramak

CEO

Tax Advisor

aneta.saramak@arenatax.pl

tel. +48 603 700 015

Licensed Tax Advisor (No. 10068), finance expert, with over 19 years of experience in providing tax advisory for financial institutions.

Work experience & education

Aneta worked for KPMG and Deloitte where she was involved in tax advisory for financial institutions, mainly banks, non-banking lending institutions, debt collection entities, leasing companies, and brokerage houses. She was responsible for on-going tax advisory for Polish and multinational financial institutions involving issues in the scope of income taxes and indirect taxes, as well as international taxation. She was responsible for complex tax audits and due diligence tax reviews, carried on restructuring projects and strategic tax planning projects, regarding for example transfer of portfolios of receivables, organizational restructurings (bank into branch), tax planning of insurance being sold together with bank or leasing products (bancassurance). Aneta represented clients before tax authorities and administrative courts in course of tax proceedings.

She runs numerous tax trainings, in particular for financial institutions, author of press publications, co-author of the Tax Commentary C.H. Beck Corporate Income Tax. 2014, 2015 Commentary.

 

Languages

Polish, English

Joanna Deutryk

Director, Transfer Pricing / Group CSO

Tax Advisor

joanna.deutryk@arenatax.pl

tel. +48 503 631 355

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Joanna Deutryk

Director, Transfer Pricing / Group CSO

Tax Advisor

joanna.deutryk@arenatax.pl

tel. +48 503 631 355

Licensed Tax Advisor (No. 12230) with 13 years of professional experience in transfer pricing and tax advisory for multinational groups.

Work experience & education
Joanna is a graduate of Warsaw School of Economics which she completed in 2002 with two Master’s degrees in Management and International Relations. She started her career in Rome at a major Italian bank and later for the Italian Ministry of Finance. Next she worked for a tax advisory firm where she ran transfer pricing projects. Joanna assisted Italian and German companies in regard to transfer pricing compliance in the Master File-Local File model. In Poland she was part of the transfer pricing of KPMG Poland, later she was Tax Manager at a Polish tax advisory firm part of a global network of advisory firms specialized in transfer pricing. Joanna managed projects involving benchmarking studies, transfer pricing documentation files, provided advisory in regard to transfer pricing and conducted transfer pricing reviews for multinational companies and companies listed on the Warsaw Stock Exchange. She cooperated on applications concerning the Advanced Pricing Agreements. Her most important transfer pricing projects regarded a restructuring transaction with a complex value of 256 m Euro.

In Arena Tax she manages the transfer pricing team. She is also responsible for the strategic development of the Group.

 

Languages
Polish, English, German, Italian

Dominika Ramírez-Wołkiewicz

Manager

Tax Advisor, Attorney at Law

dominika.ramirez@arenatax.pl

tel. +48 503 630 046

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Dominika Ramírez-Wołkiewicz

Manager

Tax Advisor, Attorney at Law

dominika.ramirez@arenatax.pl

tel. +48 503 630 046

Attorney at law (WA-9807) and licensed Tax Advisor (No. 10092) with over 18 years of professional experience in legal and tax advisory services.

Work experience & education
Dominika is a graduate of the Faculty of Law and Administration of the Maria Curie-Sklodowska University in Lublin.
She gained professional experience in an international law and audit firms. She worked in the Deloitte’s tax advisory department since 2004 until 2014. Taxing activity of financial institutions was principal area of her work.
Dominika primarily dealt with providing complex day-to-day tax advisory for entities from both a financial sector and FMCG. She participated in tax optimization and restructuring projects included international entities and also conducted complex tax reviews. Dominika represented the clients before the tax authorities and administrative courts. She led of numerous training courses and tax conferences.

 

Languages
Polish, English, French

Michał Chyła

Manager

Tax Advisor

michal.chyla@arenatax.pl

tel. +48 603 700 146

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Michał Chyła

Manager

Tax Advisor

michal.chyla@arenatax.pl

tel. +48 603 700 146

Licensed Tax Advisor (No. 12827) with 12 years of experience in providing tax advisory for financial services industry.

Work experience & education
Michał graduated Faculty of Law and Administration of University of Gdańsk. Before joining Arena Tax for over 8 years he worked at Deloitte tax advisory department where he mainly dealt with issues relating to the taxation of financial institutions.
He has been dealing with tax matters for over 12 years, most of which has been devoted to tax issues in financial services industry. He has managed to accumulate wide experience in providing advisory services on corporate income tax, personal income tax, VAT, tax on civil law transactions and international taxation with a special focus on the issues characteristic for entities that operate on the financial market. Michał has extensive experience in the analysis of the tax consequences of the products offered by banks and insurance companies, and other issues arising in the current operations of financial institutions. He participated in tax restructuring projects, tax reviews and due diligence reviews. He also dealt with issues related to the development and implementation of optimal tax structures for obtaining financing, disposal of assets and debts trading.
Michał has participated as a speaker at numerous conferences and trainings, which were devoted to tax issues occurring in financial institutions. He is also the author of a press publications regarding tax issues.

 

Languages
Polish, English

Natalia Michoń

Manager

Tax Advisor

natalia.michon@arenatax.pl

tel. +48 504 306 696

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Natalia Michoń

Manager

Tax Advisor

natalia.michon@arenatax.pl

tel. +48 504 306 696

Licensed tax advisor (No. 12802) with extensive experience in tax consultancy.

Work experience & education

Before working in Arena Tax Natalia was a Tax Consultant in the KPT Doradcy Podatkowi. Natalia specializes in tax advisory for Polish institutions and international tax structures. One of her main interests is the taxation of financial derivatives. She prepared many complex projects regarding restructuring of enterprise activity, including projects with participation of foreign entities. She carried out numerous tax reviews in the target of CIT and VAT, including analysis of tax settlements in the financial institutions such as banks and digital lending companies. She also conducted due diligence reviews. Natalia has experience in tax advisory for banks and companies from FMCG, investment and energy sector.

Natalia also gained experience in one of the consulting companies in tax compliance and tax accounting services, where she was responsible for tax reporting in the target of CIT and VAT as well as day to day tax support for large, international group of companies from IT, automotive and real estate sector.

She graduated from the Warsaw School of Economics with a degree in finance and accounting. Currently. Natalia is studying law at Kozminski University.

Languages
Polish, English

Jakub Patalas

Transfer Pricing Manager

jakub.patalas@arenatax.pl

tel. +48 502 049 678

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Jakub Patalas

Transfer Pricing Manager

jakub.patalas@arenatax.pl

tel. +48 502 049 678

Manager specializing in transfer pricing and advisory for capital groups.
Work experience & education
Jakub is a graduate of the Warsaw School of Economics, faculty of Finance and Accounting and University of Warsaw, faculty of International Economics. Under the Erasmus Program he studied also at Università degli Studi di Padova, Italy.
He started his career in the Financial Services Audit Department at KPMG, and later worked in transfer pricing teams of Ernst & Young and Andersen Tax, where he was responsible for implementation of transfer pricing and international tax projects.
Jakub conducted a number of projects involving benchmarking studies, benchmarking of financial instruments, preparation of Local File and Masterfile documentation, preparation of economic and financial analyses of companies and valuation of royalties. He worked for entities from finance, technology, pharmaceutical and development sectors. During his professional career Jakub was involved in projects including: preparation of applications concerning the Advanced Pricing Agreements, preparation of transfer pricing policies and structuring of settlements between companies from international capital groups, assistance in transfer pricing controls of companies, preparation of defense file documentation for entities generating revenues exceeding 1 bln EUR.
In Arena Tax he coordinates and manages the work of transfer pricing team members and is responsible for transfer pricing projects realised by the team.
Languages
Polish, English

Agata Czerniak

Manager

Tax Advisor

agata.czerniak@arenatax.pl

tel. +48 506 306 756

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Agata Czerniak

Manager

Tax Advisor

agata.czerniak@arenatax.pl

tel. +48 506 306 756

Licensed tax advisor  (No. 13135) with vast professional experience in tax advisory services. Agata focuses her practice on tax disputes and ongoing tax advisory.
Work experience & education
Agata graduated law from the University of Warsaw and currently she is a PhD Candidate in the Institute of Administration Law at Faculty of Law and Administration at the UW. Her area of research work is focused on the procedural aspects concerning the transfer pricing regulations. She is also a graduate of the International Tax Law School organized by the WU Vienna University of Economics and Business.
Agata’s professional experience includes providing comprehensive advice on tax matters, especially those matters relating to corporate income tax and value-added tax including transfer pricing regulations. She advised on number of tax inspections and due diligence reviews, and represented clients in front of tax authorities and administrative courts.
Before joining Arena Tax she worked in PwC and in other reputable tax advisory companies where he provided tax advisory for the entities from IT, FMCG, real-estate, energy, logistic and transport industries.
Languages
Polish, English

Aleksandra Chojnacka

Transfer Pricing Manager

Tax Advisor

aleksandra.chojnacka@arenatax.pl

tel. +48 509 954 271

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Aleksandra Chojnacka

Transfer Pricing Manager

Tax Advisor

aleksandra.chojnacka@arenatax.pl

tel. +48 509 954 271

Licensed tax advisor (No. 13448), tax law practitioner with over 13 years of professional experience in tax audit authority and tax authorities who specializes in transfer pricing.
Work experience & education
Aleksandra graduated from the University of Lodz in Finance and Banking with a specialty in Tax Strategies. She also completed postgraduate studies in Accounting and Corporate Finance at the Warsaw School of Economics and Tax Law at the Faculty of Law and Administration of the University of Lodz. Aleksandra is a PhD student at the Collegium of Management and Finance at the Warsaw School of Economics.

She started her professional career at the Tax Inspection Department in the Tax Office by conducting audits in the field of ​​ goods and services tax, and personal income tax. Then she worked at the Tax Control Department of the Tax Control Office in Warsaw, where she was mainly involved in corporate income tax, including transfer pricing. For the past year and a half, Aleksandra has run the TP team in a tax advisory company dedicated to transfer pricing. She has carried out a number of projects for multinational enterprises, including the largest players from many industries, such as: financial, metal, pharmaceutical and TSL (Transport, Shipping and Logistics). She specializes in financial transactions.

She is an experienced trainer of trainings in the field of transfer pricing. In October 2018, there was the publication of her co-authorship published, entitled “Transfer prices. 259 explanations and interpretations.” by Wolters Kluwer.

At Arena Tax, she manages the work of the transfer pricing and valuation team and is responsible for projects carried out by the transfer pricing team.

Languages
Polish, English

Careers

We have created a place, where work is not only a challenge but also pleasure

If you are a student or you recently graduated from law or economy (both faculties would a great asset) and are fluent in English, we invite you to join our team. We also encourage tax advisors with at least 3 years of experience in providing services to legal persons to submit their applications.

If you are interested, send us your CV and covering letter on our e-mail address rekrutacja@arenatax.pl with a clause “I hereby give consent for my personal data to be processed for the purposes of recruitment, in accordance with the Personal Data Protection Act dated 29.08.1997 (uniform text: Journal of Laws of the Republic of Poland 2002 No 101, item 926 with further amendments)”

 

Contact

Arena Tax Sp. z o.o.
Tax Advisory Company
ul. Bukowińska 22B , 02-703 Warszawa
google maps

tel. +48 22 102 20 30
e-mail: office@arenatax.pl

KRS: 0000421071 | NIP: 5213631253 | REGON: 146123519

Registered in XIII Commercial Department of the District Court in Warsaw
Share capital: PLN 50,000

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