T A X R E S I L I E N C E A R C H I T E C T U R E

Maria Bernadeta Uchman

I am a Polish tax advisor

specializing in international tax law

International Tax Advisory

A person sitting at a desk using a laptop computer
Black and white portrait of a middle-aged woman with shoulder-length hair, wearing a suit jacket and white shirt, sitting on a chair, resting her chin on her hand, with a neutral background.

01 TAX RESIDENCY

__

Your tax residency determines where and how your income is taxed

The question of where you live is a legal one

Determining and planning tax residence ‍→

Areas of my practice

02 CROSS- BORDER BUSINESS STRUCTURES

__

Cross-border business structures that create value are based on economic substance and legal compliance

If it is different, then it is exposure to risk

Strategic tax planning →      ‍

"Property requires architecture. Life requires sovereignty"

T A X R E S I L I E N C E

A R C H I T E C T U R E

03 TRANSFER PRICING

The market-based shaping of transactions between related parties, based on transfer pricing compliance and documenting transactions for tax purposes, is the most important tool for managing tax base stability risk

___

Strategic linkage risk management project →

04 TAX PROCEDURES

MAP

Mutual Agreement Procedure

APA

Advance Pricing Arrangement

Contact→


BIO

Double taxation is an inherent part of the international environment. Single level taxation is the result of consciously managing your tax situation.

My strength stems from my in-depth knowledge of the law and my extensive experience in litigating disputes with tax authorities.

I create balanced, comprehensive solutions based on legal principles, thoughtful tax risk management, economic substance, and a realistic assessment of litigation opportunities. Protecting property rights is my primary motivation.