Przemysław Szot

Przemysław Szot is a partner at Tax Legal Partner, an attorney-at-law and a licensed tax advisor. He advises on Estonian CIT (estoński CIT, Poland’s lump-sum tax on company income), on support decisions in the Polish Investment Zone (Polska Strefa Inwestycji, PSI) and on tax reliefs, and he runs both the implementation and the settlements that follow it. He also handles company reorganizations, family foundations and succession, employment law for employers, and the taxation of transactions with foreign entities. He advises in Polish, English, German and French.

Moving to Estonian CIT, applying for a support decision in the Polish Investment Zone or claiming a tax relief is not a one-off decision. It is a commitment that runs for several years. The benefit is visible immediately, the obligations only after the first year, and those are the ones easiest to forget until an audit asks about them. I run these implementations together with the ongoing settlements for the whole period the scheme applies, so that what we calculated at the start stays with you to the end.

A conversion, merger or demerger rarely starts with tax. It starts with a business decision: you want to separate risk, bring in a partner, prepare the company for sale. Tax appears as the cost of that change, and it usually turns out that the same reorganization carried out in a different sequence costs less. I therefore build it around the outcome you want rather than around a ready-made template. In succession the sequence matters even more. Before you transfer assets into a family foundation (fundacja rodzinna) or decide who takes the shares, we establish what has to happen first, because some of those steps cannot be reversed.

Employment decisions sit in a separate category. When you dismiss someone, set bonus rules for the management board or restructure a team, your decision is judged by a labor court rather than by the tax authority, and it is judged on documents that were drafted earlier. I draft contracts, internal policies and resolutions so that at that moment they stand on your side.

Every one of these decisions costs less to analyse properly than to repair afterwards, and some cannot be repaired at all. So you will not hear from me that something usually pays off. You will hear how much you gain, what it will require from you over the coming years, and where it can fail. With that, the decision is yours, and you can justify it to a board, to your co-owners or to your family.

The same logic applies to transactions with foreign entities. A settlement can be beyond dispute in Poland and still be challenged by the tax administration of the other country, which assesses it under its own rules, so before you adopt a position I check whether it holds on both sides of the border. I advise in English, German and French as well as Polish, which means you discuss the numbers directly with the person who calculated them rather than through a translation of them.

Before I open the legislation, I listen. What do you want to achieve, and by when. Then I calculate. With Estonian CIT and the Polish Investment Zone you get a clear statement of the benefits, the obligations and the risks, before implementation rather than after, together with my recommendation on which option fits your case. You get one recommendation, with the reasoning behind it, so the judgement does not land back on your desk as a table of variants.

With a family foundation, the objective sets the structure, so that is where I start. Protecting assets from being divided between heirs calls for one design. Having one child run the company while the others share in the profits calls for another. Once the objective is clear, I take the matter through to the end: I prepare the documents and set the order of the steps.

Employment law works the same way. Parting with an employee is not prepared like a dispute over liability for damage, and restructuring headcount across a group is not prepared like setting board remuneration. I tell you plainly how to carry out the decision, and what not to do alongside it. The documents are drafted for that scenario, not to a general template.

In each of these I stay with the matter past the decision itself, into the settlements and the obligations that follow it. That is usually where the cost of a scheme is decided.

• Choice between Estonian CIT, a support decision in the Polish Investment Zone and a tax relief, before the investment starts
• Exemption in the Polish Investment Zone or Estonian CIT already in place, where the settlements have to be run to reduce the risk that an audit challenges the benefit obtained
• Transaction with a foreign entity, or a question about applying a double tax treaty and withholding tax
• Conversion, demerger or merger of a company whose tax consequences you want to know before the reorganization takes effect
• Succession in a family business and the decision whether a family foundation is the right structure to protect the assets
• Employment decision that may end in a dispute: a dismissal, a change to remuneration rules or a restructuring of headcount
• Investment by a local authority or an EU-funded project in which the VAT settlement determines how much actually stays in the budget

Planning an investment, a succession in a family business, a restructuring of employment or a cross-border transaction? Before you decide, find out what it is really worth and what it will require. A first conversation is enough to identify what must be quantified in the benefit and the risk before you commit time and money.

• Estonian CIT
• Polish Investment Zone and support decisions
• Tax reliefs, including research and development relief and expansion relief
• Business reorganization: conversions, mergers, demergers
• Family foundations and succession
• Employment law for employers
• International taxation and withholding tax
• Corporate income tax
• VAT for local government units
• Legal and tax due diligence
• Mandatory disclosure of tax arrangements (MDR)
• Excise duty

Author and co-author of titles published by C.H.Beck, Poland’s leading legal and tax publisher:

• B2B contracts in practice: legal, tax and social security aspects, 2026
• The family foundation: legal, tax and accounting treatment, 2025
• Estonian CIT: the lump-sum tax on company income, editions of 2023 and 2025
• Tax reliefs: deductions, exemptions and other preferences in PIT and CIT, 2023
• The personal income tax remitter: payroll after the Polish Deal reforms, 2022
• A series of C.H.Beck publications on family foundations and tax reliefs, 2022 to 2025
• Tax articles on VAT and on deductible costs in new media businesses, among other subjects

• Attorney-at-law, registered by the Kraków Bar Association of Attorneys-at-Law under no. KR-5379
• Licensed tax advisor, registration no. 14378
• Cracow University of Economics, law

Polish, English, German, French