Get the RET right

The tax side of real estate
Periodic newsletter for the Real Estate sector

October 2021

Companies that rent apartments for the residential purposes of their employees will have to pay VAT, according to the general ruling issued by the Minister of Finance on October 08, 2021 (PT1.8101.1.2021)
The ruling concerns taxpayers that rent apartments and then sublease them to others for residential purposes.
“Summing up, services that consist in the lease of residential property (e.g. apartments) or part thereof, rendered by an active VAT payer to an individual/entity (…) that uses such leased property for the purposes of business operations, e.g. by subleasing it to others for residential use, are subject to taxation at the basic VAT rate,” noted the Minister of Finance.

It is possible to contest the entries made in the land and building register with respect to buildings through reference to evidence and documents on the basis of which such entries are made, according to the ruling issued on October 13, 2021 by the Supreme Administrative Court (case files no. III FSK 225/21)
The case concerned a company that owns an office building categorized in the land and building register as a commercial development. The company claimed that in fact, the building serves residential and commercial purposes alike. While the Supreme Administrative Court upheld the prior ruling (which was unfavorable for the company) because the site visit had shown that the building did not actually have a residential function, it nonetheless admitted the possibility to challenge the building categorization in the land and building register if it does not reflect the real status.

An amount paid for the consent for early termination of a lease agreement should be considered as a fee for services, which is subject to VAT, according to the advance tax ruling issued on September 23, 2021 by the President of the National Fiscal Information (0112-KDIL3.4012.264.2021.1.AW)
The case concerned an agreement between the lessor and tenants, on the basis of which one of the tenants was obliged to pay a specific fee in return for the lessor’s consent for early termination, and for the resulting waiver of further obligations. The tenant retains the right to deduct VAT. The authority did not provide
a statement of reasons to the ruling.
An important issue was brought up by taxpayers that submitted the application for the advance tax ruling: “The legal relationship between X and Y (i.e. the parties to the agreement) involves reciprocal services. It needs to be noted that (as indicated above) Y is going to receive the Fee specified in Agreement II for its consent for X’s sanctionless termination of the Lease Agreement. Consequently, there is a direct and tight link between Y’s consent and the Fee due to Y for that consent.”
“The ruling confirms the existing practice of tax authorities which assume that payment of a fee for early termination of an agreement should be categorized as services, as long as such fee is intrinsically related to a specific action taken by the other party,” commented Małgorzata Wąsowska, Head of Tax and Tax Advisor at act BSWW legal & tax.

Real estate tax has to be paid on the entire company building that is included in the register of fixed assets, even if, in fact, only part thereof is used for business operations, according to the rulings issued on October 07, 2021 by the Supreme Administrative Court (case files no. III FSK 121/21 and III FSK 122/21)
The owner of a wholesale facility was only using part of its building for the purposes of business operations. Nevertheless, after an occupancy permit was obtained, the entire building was listed in the company’s register of fixed assets. The Supreme Administrative Court decided that the actual use of the building was irrelevant because what matters is the fact that it is included in the register of fixed assets. As a result, it is necessary to pay real estate tax on the entire building, at the rate applicable to buildings intended for business activity.

The value (introduced in 2018) of the excess of financing costs that are not subject to the so-called thin capitalization (article 15c of the CIT Act) is determined as the total sum of PLN 3 million and 30% of taxable EBITDA, according to the ruling issued on October 20, 2021 by the Supreme Administrative Court (case files no. II FSK 390/19)
As of now, tax authorities tend to assume that the value of the excess of financing costs, which is excluded from the thin capitalization regulations, should be set at PLN 3 million or 30% of EBITDA. On the other hand, administrative courts predominantly decide that such value should correspond to PLN 3 million and 30% of EBITDA.
“I hope that the favorable (from the taxpayers’ perspective) ruling of the Supreme Administrative Court will be reflected in the approach taken by tax authorities. It needs to be noted, however, that starting from 2022, the value of the excess of financing costs which are not covered by thin capitalization will be set at the higher of PLN 3 million or 30% of EBITDA,” commented Michał Brzozowicz, Tax Advisor at act BSWW legal & tax.

The municipality’s return of expropriated real estate should not be regarded as a supply of goods and is not subject to VAT because such return is made as part of reinstatement of the pre-expropriation status, according to the ruling issued on October 26, 2021 by the Supreme Administrative Court (case files no. I FSK 119/18)
The return of real property should not be aligned with the supply of goods, as defined in the VAT Act. Consequently, such return is not VAT-taxable. The amount paid by heirs as part of property restitution is not categorized as compensation.

The application of PIT exemption (in case of property disposal) as a result of expenses incurred for one’s own residential purposes – categorization of certain costs related to renovation and adaption (fit-out) – the general ruling issued by the Minister of Finance on October 13, 2021 (DD2.8202.4.2020)
The Minister of Finance has recently issued a general ruling based on which expenses incurred to purchase and install (among others) household appliances, ceiling/wall lighting, kitchen hoods, custom-made furniture and kitchen furniture fit within the definition of costs intended for residential purposes, and can thus be included in the calculation of the tax exemption base.
“Given their functionality and intended purpose, this equipment should be regarded as an intrinsic part of a residential building (unit). In order for a building (unit) to serve residential premises, it needs to be adjusted to satisfy the basic life needs. It has to be highlighted here that the equipment aimed at fulfilling those needs should not include the so-called “small household appliances,” such as coffee makers, toasters, microwaves, etc. These are just accessories, rather than indispensable elements without which a kitchen would lose its functionality,” concluded the Minister of Finance.
“In my opinion, this general ruling is a clear sign for taxpayers that will soon be obliged to settle their housing tax relief. Importantly, the Minister of Finance focuses on the social aspects of basic residential purposes (as shown by the coffee maker example), rather than the connection between a specific cost and the real property,” commented Szymon Kokot, Tax Advisor at act BSWW legal & tax.

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Małgorzata Wąsowska
Tax Advisor / Partner / Head of Tax
+48 691 477 047
malgorzata.wasowska@actlegal-bsww.com

Michał Brzozowicz
Tax Advisor / Attorney-at-law / Senior Associate
+48 665 667 110
michal.brzozowicz@actlegal-bsww.com

Jakub Świetlicki vel Węgorek
Tax Advisor / Senior Associate
+48 505 703 768
jakub.swietlicki@actlegal-bsww.com

Szymon Kokot
Tax Advisor / Trainee Attorney-at-law / Associate
+48 691 557 507
szymon.kokot@actlegal-bsww.com

Get the RET right

The tax side of real estate
Periodic newsletter for the Real Estate sector

September 2021

Services related to long-term lease should be covered by the 8% VAT rate, according to the so-called “binding rate information” issued on September 20, 2021 by the President of the National Fiscal Information (0112-KDSL2-1.440.103.2021.2.MK).
The case concerned the VAT rate applicable to the accommodation of students, workers and others.
“According to PWN [Polish Scientific Publishers] Polish dictionary, to ‘accommodate’ means ‘to provide temporary lodging for someone.’ These services are covered by code no. 55 in PKWiU [Polish Classification of Goods and Services] – Accommodation-related services. The VAT Act sets a preferential VAT rate of 8% for such services – article 41 section 2, in conjunction with article 146aa section 1 item 2 and section 1a of the Act, and item 47 of Appendix 3 to the Act,” noted the President of the National Fiscal Information.
“Once again the President of the National Fiscal Information confirmed the possibility to apply the 8% VAT rate for services related to the private rented sector,” commented Małgorzata Wąsowska, Head of Tax and Tax Advisor at act BSWW legal & tax.

Contractual penalties paid for rescission of lease agreements might sometimes be regarded as tax-deductible costs, according to the advance tax ruling issued on August 31, 2021 by the President of the National Fiscal Information (0111-KDIB1-3.4010.498.2017.6.MBD).
The case concerned a company which concluded (following a thorough analysis) that its operations performed in leased premises might be unprofitable, i.e. may result in losses. The President of the National Fiscal Information confirmed that is such case, the payment of contractual penalties is related to maintaining the source of income, and that article 16 section 11 item 22 of the CIT Act does not apply to those penalties.
“(…) Given the fact that contractual penalties under lease agreements match the definition of tax-deductible costs discussed in article 15 section 1 of the CIT Act, and do not meet the criteria applicable to the penalties discussed in article 16 section 1 item 22 of the CIT Act, the Applicant will be entitled to categorize them as tax-deductible costs,” concluded the President of the National Fiscal Information.

In order to apply the housing tax relief before December 31, 2018, it was enough to sign a development agreement and use the funds for residential purposes within 2 years of the date of sale of the previous property, according to the general ruling issued by the Minister of Finance on September 02, 2021 (DD2.8202.1.2021).
“The right to apply the relief is independent from the final acquisition of the ownership right within the deadline specified in article 21 section 1 item 131 of the CIT Act, effective until December 31, 2018,” noted the Minister of Finance.
“This general ruling puts an end to the doubts as to whether the final transfer of the ownership right to real estate until the statutory deadline was required in order to tap into the housing tax relief. The ruling confirms the well-established judicial practice in this respect,” commented Jakub Świetlicki vel Węgorek, Tax Advisor at act BSWW legal & tax.

While selling a real property, a natural person who does not conduct business operations may act as a VAT payer as a result of the powers of attorney and conditions precedent, according to the advance tax ruling issued by the President of the National Fiscal Information on August 31, 2021 (no. 0111-KDIB1-3.4010.498.2017.6.MBD).
The case concerned a natural person who intended to sell a property and authorized the purchaser to obtain the decisions and permits which constituted the conditions precedent for execution of the final agreement, to obtain the utilities connection conditions, to get a construction permit, and to subdivide the property.
“It needs to be noted that the actions which have been taken by the Applicant preclude the sale of land lot no. 1 as part of management of private assets. Hence, the aforesaid sale will be deemed to form part of business operations, as discussed in article 15 section 2 of the Act, and the Applicant will be acting as a VAT payer, as referred to in article 15 section 1 of the Act,” noted the President of the National Fiscal Information.

Establishment of a free-of-charge transmission easement to the benefit of a company shall be regarded as such company’s revenue from free-of-charge services under article 12 section 1 item 2 of the CIT Act, according to the advance tax ruling issued on September 22, 2021 by the President of the National Fiscal Information (0111-KDWB.4010.29.2021.1.ES).
The case concerned a company which builds heat networks and enters into connection agreements with new recipients. In order for such agreements to be executed, it is necessary to establish transmission easements. The heating system and equipment serve the purpose of supplying heat to recipients, i.e. owners and holders of perpetual usufruct right to properties. Thanks to the easement, the company has the right to enter the land in case of any need to perform inspections, repairs or maintenance. As a result, the company can operate, and the recipients can be supplied with heat, in an uninterrupted manner.
“Taking the above into consideration, it has to be concluded that establishment of a free-of-charge transmission easement to the benefit of the company, consisting in the right of access to the property and use thereof, generates revenues arising from free-of-charge services under article 12 section 1 item 2 of the CIT Act,” decided the President of the National Fiscal Information.

Demolition of the acquired buildings in order to implement another project will not entail an obligation to revise input VAT, according to the advance tax ruling issued on September 08, 2021 by the President of the National Fiscal Information (0114-KDIP1-1.4012.362.2021.2.JO).
The case concerned a taxpayer that intends to acquire developed land in order to implement a new project promptly after demolition of the existing developments. The President of the National Fiscal Information fully shared the taxpayer’s opinion that “there is no obligation to revise input VAT due to demolition of the building or structures; this applies to the VAT amount included in the invoice received from the seller, covering the sale of the assets, deducted in relation to the acquisition thereof.”

A “structure,” as defined in construction law regulations, may be regarded as a building under the Local Taxes and Fees Act for the purposes of the property tax if it meets the criteria included in the “building” definition provided in that Act, and its distinctive element is the usable area, according to the resolution adopted by the Supreme Administrative Court on September 29, 2021 (case files no. III FPS 1/21).

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Małgorzata Wąsowska
Tax Advisor / Partner / Head of Tax
+48 691 477 047
malgorzata.wasowska@actlegal-bsww.com

Michał Brzozowicz
Tax Advisor / Attorney-at-law / Senior Associate
+48 665 667 110
michal.brzozowicz@actlegal-bsww.com

Jakub Świetlicki vel Węgorek
Tax Advisor / Senior Associate
+48 505 703 768
jakub.swietlicki@actlegal-bsww.com

Szymon Kokot
Tax Advisor / Trainee Attorney-at-law / Associate
+48 691 557 507
szymon.kokot@actlegal-bsww.com

Get the RET right

The tax side of real estate
Periodic newsletter for the Real Estate sector

August 2021

The lease of hotel/commercial premises for residential purposes will be subject to VAT and non-exempt, according to the advance tax ruling issued on August 05, 2021 by the President of the National Fiscal Information (no. 0112-KDIL1-2.4012.265.2021.2.DS).
The case concerned the possibility to apply VAT exemption to the lease of hotel/commercial premises for residential purposes (incl. with respect to students and seconded employees).
“(…) VAT exemption only applies to the lease of residential properties for residential purposes,” concluded the President of the National Fiscal Information.
“This advance tax ruling is important with respect to the long-term lease of premises in condo hotels and apartment hotels, especially in terms of the right to deduct VAT related to their construction and acquisition,” commented Małgorzata Wąsowska, Head of Tax and Tax Advisor at act BSWW legal & tax.

The use of the company’s infrastructure by its manager might sometimes result in the lack of the right to deduct VAT, according to the advance tax ruling issued on August 04, 2021 by the President of the National Fiscal Information (no. 0112-KDIL1-1.4012.368.2021.1.AR).
The case concerned a natural person who was appointed as a member of the management board, while at the same time performing management services under a separate agreement. Given the fact that pursuant to the agreement, the manager is entitled to use the company’s infrastructure, receives a fixed fee and does not bear liability towards third parties, he was unsure whether he was acting a VAT payer.
“(…) As part of the agreement with the Company, the Manager is / will be bound by the legal relation with the entity that requests the performance of specific tasks as regards the conditions applicable to such performance, the remuneration and the aforesaid entity’s liability towards third parties,” noted the President of the National Fiscal Information, deciding that the manager does not act as a VAT payer, meaning that the services performed by him will not be covered by VAT.

A company that leases residential premises to students in its own building should pay the property tax in the same way as for premises intended for business operations, according to the Provincial Administrative Court in Gliwice (judgment of July 14, 2021, case files no. I SA/Gl 487/21).
The Provincial Administrative Court decided that if the Company had not leased premises, it would not have generated income from business operations. Consequently, the lease of premises for residential purposes is not crucial for taxation purposes.
“In order to apply an adequate property tax rate, it is vital to take into account the company’s object of business, and (consequently) the role that a residential building (student house) plays in generating the results of such operations, i.e. profits. Without using the residential building or its part, the company will be unable to reach its business goals, meaning that in the case at hand, the building is occupied for the purposes of the company’s business operations,” concluded the Provincial Administrative Court in Gliwice.

The sale of a share in the perpetual usufruct right to a real property is not regarded as business operations as there are no criteria pointing to the taxpayer’s professional activity, according to the Provincial Administrative Court in Warsaw (judgment of February 10, 2021, case files no. III SA/Wa 658/20).
The taxpayer wanted to sell the right of perpetual usufruct as part of management of private assets. In relation to the executed lease agreement and the actions taken with respect to the property, the authority decided that the taxpayer acts as an entity that is not subject to VAT.
“Summing up, it needs to be concluded that under the circumstances specified in the case description, the planned sale of a share in the perpetual usufruct right to the Property will not constitute business operations that are subject to VAT as there are no criteria pointing to the Applicant’s activity that would be comparable to the activity of entities whose professional operations cover such transactions. There are no reasons to believe that such actions are professional, regular and organized in nature,” noted the Provincial Administrative Court in Warsaw.
“This judgment shows that not every single sale of a real property needs to be automatically regarded as made as part of business operations. It is always necessary to analyze a range of circumstances related to the transaction,” commented Michał Brzozowicz, Tax Advisor at act BSWW legal & tax.

Income from participation in a limited partnership [spółka komandytowa] through an ordinary partnership [spółka jawna], generated by a natural person, is not subject to the so-called solidarity levy, according to the advance tax ruling issued on June 09, 2021 by the President of the National Fiscal Information (no. 0113-KDIPT2-3.4011.308.2021.1.MS).
The case concerned a natural person who is a partner in an ordinary partnership and generated income from participation in the profits of a limited partnership (through the ordinary partnership). The authority believes that such income is not included in the taxation base for the purposes of the solidarity levy.
“The Applicant’s income (revenue) from participation in the profits of a limited partnership, generated through the ordinary partnership, will not be taken into account when determining the taxation base related to the solidarity levy,” concluded the President of the National Fiscal Information.

Independent residential unit owned by the Company are not regarded as buildings, and are this not covered by income tax on revenues from a fixed asset (building) referred to in article 24b section 1 of the CIT Act, according to the advance tax ruling issued on August 26, 2021 by the President of the National Fiscal Information (no. 0111-KDIB1-2.4010.253.2021.1.ANK).
The case concerned a company that owns independent residential premises that are successively sold to tenants. While selling those apartments, the company establishes a separate ownership title to them.
“It needs to be noted that if the tax referred to in article 24b of the CIT Act (effective as of January 01, 2019) was supposed to cover independent residential units that are subject to a separate ownership right, the lawmaker would make that clear through an unequivocal legal regulation that refers specifically to residential units categorized as separate property,” concluded the President of the National Fiscal Information.

In order to decide that a given entity meets the criteria of a “real estate company,” all applicable statutory requirements have to be fulfilled, according to the advance tax ruling issued on August 24, 2021 by the President of the National Fiscal Information (no. 0111-KDIB1-2.4010.235.2021.1.AK).
The case concerned an SPV that had doubts as to whether the sale of its shares, held by a Dutch tax resident, will mean that it is subject to CIT in Poland even though it does not generate revenues from lease, and the balance sheet value of the property in the preceding year did not exceed PLN 10 million.
“Given the fact that the Applicant does not meet the criteria for being classified as a ‘real estate company,’ as defined in article 4a item 35 of the CIT Act, it will not be obliged to pay a tax advance in relation to the Transaction under article 26aa section 1 of the CIT Act,” concluded the President of the National Fiscal Information.

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Małgorzata Wąsowska
Tax Advisor / Partner / Head of Tax
+48 691 477 047
malgorzata.wasowska@actlegal-bsww.com

Michał Brzozowicz
Tax Advisor / Attorney-at-law / Senior Associate
+48 665 667 110
michal.brzozowicz@actlegal-bsww.com

Jakub Świetlicki vel Węgorek
Tax Advisor / Trainee Attorney-at-law / Associate
+48 505 703 768
jakub.swietlicki@actlegal-bsww.com

Szymon Kokot
Trainee Attorney-at-law / Associate
+48 691 557 507
szymon.kokot@actlegal-bsww.com

Get the RET right

The tax side of real estate
Periodic newsletter for the Real Estate sector
June 2021

It is the taxpayer’s decision whether a leased property belongs to personal assets or is considered as an asset related to business operations, according to the resolution of the Supreme Administrative Court of May 24, 2021 (case files no. II FPS 1/21).
The case concerned the allocation of lease income to the right source, and its connection with business operations.
“Lease income (…) is categorized, without any restrictions, as the income source specified in article 10 section 1 item 6 of the Personal Income Tax Act of July 26, 1991 (Dz. U. / Journal of Laws of 2020, item 1426, as amended), unless it has been added by a natural person to assets related to business operations,” concluded the Supreme Administrative Court.

The lessee’s approval of the lease conditions suggested by the lessor in return for a specific fee shall be regarded as VAT-taxable services, according to the advance tax ruling issued by the President of the National Fiscal Information on February 03, 2021 (no. 0114-KDIP4-1.4012.661.2020.2.AM).
The case concerned a lessor that agreed to pay a one-off fee to the lessee as an incentive to enter into the lease agreement.
“The purpose of the incentive is for the lessee to enter into an agreement with the Applicant, rather than any other entity. The incentive is supposed to encourage the lessee to take a specific action, i.e. to execute the lease agreement. In such case, there is a clear relation between the fee paid by the lessor (Applicant) and the lessee’s action (execution of the lease agreement). Consequently, in the case at hand, there is an element of reciprocity, one that is necessary to determine that the payment is, in fact, made for the services performed,” concluded the President of the National Fiscal Information, at the same time confirming the lessor’s right to deduct VAT from the invoice covering the aforesaid incentive.

The limitation of tax-deductible costs does not apply to services consisting in the management of investment project preparation and implementation, acquired from affiliated entities, according to the advance tax ruling issued by the President of the National Fiscal Information on June 07, 2021 (no. 0111-KDIB1-2.4010.165.2021.1.ANK).
The case concerned a company established in order to implement a development project. The company was acquiring investment project preparation /
implementation management services (among others) from affiliated entities, as defined in the CIT Act. The company had some doubts as to whether the aforesaid costs of services, regarded as the expenses discussed in article 15e section 1 item 1 of the CIT Act, capitalized to the initial value of the building recorded as a fixed asset, minus the depreciation write-offs made after the disclosure of fixed assets, and categorized by the company as tax-deductible, will still be considered as tax-deductible upon the sale of the building, whereas the limitation referred to in article 15e section 1 item 1 of the CIT Act will not apply due to the exception offered by article 15e section 11 item 1 of the CIT Act, regardless of the building’s reclassification from inventory (goods) to fixed assets.
“(…) Investment project preparation and implementation management services (…) are considered as costs related directly to the production of goods (or performance of services), as referred to in article 15e section 11 item 1 of the Corporate Income Tax Act. (…) Such services are vital for the Project and form its inherent part; i.e. if the Company had not acquired the Services, it would not have been able to develop the Project. Given the above, the Applicant’s opinion that (…) the limitation referred to in article 15e section 1 item 1 of the
CIT Act will not apply due to the exception offered by article 15e section 11 item 1 of the CIT Act, regardless of the building’s reclassification from inventory (goods) to fixed assets, should be considered as correct,” concluded the President of the National Fiscal Information.

Loans provided by a VAT payer (irrespective of the frequency and purpose of loans, or the PKD [Polish Classification of Business Activity] code) should be VAT-exempt, meaning that they should also be exempt from the tax on civil-law transactions, according to the advance tax ruling issued by the President of the National Fiscal Information on May 05, 2021 (no. 0111-KDIB3-1.4012.117.2021.3.ASY).
The case concerned a company that was not conducting lending activities, and such operations were not included in its articles of association or its listing in the National Court Register.
“If a VAT payer grants loans, such actions shall be regarded as taxable, irrespective of the frequency and purpose of the loans, or the borrower’s status. Any loans provided by a business entity in relation to its operations can be identified and categorized as related to such professional operations, which gives rise to VAT obligations, even if such activities are not covered by the entity’s object of business. (…) Given the fact, however, that such services are included in the list provided in article 43 section 1 item 38 of the VAT Act, the loan granted by the Company (Lender) to the Applicant shall be VAT-exempt,” concluded the President of the National Fiscal Information.

Rescission fee is subject to VAT, according to the advance tax ruling issued by the President of the National Fiscal Information on June 16, 2021 (no. 0113-KDIPT1-1.4012.205.2021.2.MG).
The case concerned a taxpayer that entered into a preliminary sale agreement in which the parties undertook to execute a final sale agreement within a specific deadline, save that the seller is entitled to rescind the preliminary agreement (until the date specified therein) in exchange for the return of the advance and payment of a rescission fee.
“(…) It needs to be noted that acceptance of the Seller’s rescission of the sale agreement for a specific fee should be regarded as services, as defined in article 8 section 1 of the VAT Act, meaning that the rescission fee obtained by the Applicant is subject to VAT under article 5 section 1 item 1 of the VAT Act,” concluded the President of the National Fiscal Information.

A limited partnership may apply the exemption provided in article 22 section 4 of the CIT Act to profits distributed to its limited partner, generated by the partnership after January 01, 2021, according to the advance tax ruling issued by the President of the National Fiscal Information on June 11, 2021 (no. 0111-KDIB1-1.4010.127.2021.2.EJ).
The case concerned a limited partnership whose limited partner (acting as such for over two years) is a Polish tax resident and CIT payer, holding the right to at least 10% of the partnership’s profits, save that the limited partner’s share in the profits does not result directly from the proportion between the partner’s capital contribution and the total value of all contributions; instead, it results from the limited partnership agreement.
„(…) The exemption provided in article 22 section 4 of the CIT Act shall only apply to income resulting from a share in profits of a limited partnership or ordinary partnership [spółka jawna], generated from the day when such partnership became a CIT payer,” concluded the President of the National Fiscal Information.

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Małgorzata Wąsowska
Tax Advisor / Partner / Head of Tax
+48 691 477 047
malgorzata.wasowska@actlegal-bsww.com

Michał Brzozowicz
Tax Advisor / Attorney-at-law / Senior Associate
+48 665 667 110
michal.brzozowicz@actlegal-bsww.com

Jakub Świetlicki vel Węgorek
Tax Advisor / Trainee Attorney-at-law / Associate
+48 505 703 768
jakub.swietlicki@actlegal-bsww.com

Szymon Kokot
Trainee Attorney-at-law / Associate
+48 691 557 507
szymon.kokot@actlegal-bsww.com