Tomasz Janik

Manager | Tax adviser

Email: tomasz.janik@mddp.pl
Mob.: +48 503 976 021

Expert in corporate income tax (CIT).
Handles complex projects involving cross-border taxation, intra-group settlements and investment structures.
Has experience in withholding tax (WHT) projects, including due diligence procedures, analyses of beneficial ownership and substance requirements, consolidated substance and the look-through approach. Also supports clients with MDR reporting.
Obtains opinions on the application of WHT preferences and supports clients in WHT refund proceedings in Poland and abroad.
Advised on a cross-border conversion of a company and on obtaining a protective opinion from the Head of the National Revenue Administration.
Advises on domestic and international restructurings, including contributions in kind, share-for-share exchanges, demergers by spin-off and separation, mergers, debt-to-equity conversions, datio in solutum and bond issuances.
Handles projects involving intra-group financing, refinancing, debt push-down structures, debt financing costs, timing of tax cost recognition, the Polish Holding Company regime, the shifted profits tax and the domestic minimum tax.
Advises on investment entry and exit transactions, including share deals and asset deals, as well as exits through liquidations and share redemptions.
Advises investment funds on investment structures and CIT exemptions.
Focuses particularly on the real estate and renewable energy sectors, supporting investors, developers, private equity funds and financial institutions.

2026 | Tax adviser
2020 | Warsaw School of Economics, major: taxes in domestic and international commercial transactions
2017 | Lazarski University, major: law
Languages: Polish, English