Advice to renewable
energy sector stakeholders

Continuous growth in the renewable energy sector brings numerous challenges for businesses operating in this field.The year 2025 will see changes to real estate tax regulations, while complex rules related to CIT/PIT, VAT, excise duties, and transfer pricing add further obstacles. Our experts provide full tax and accounting support for entities in the RES sector, and through cooperation with an international law firm, we also offer comprehensive legal advisory services.

Our advisory services are directed at investors, renewable energy producers, energy companies, and private equity funds seeking to capitalize on opportunities in the Polish RES market. With our support, clients can focus on achieving their business goals.

Why Poland?

 Poland’s energy policy aims to achieve the following electricity production targets by 2040:

approx.

from zero-emission sources (renewables and nuclear power)

approx.

from renewable energy

nearly

from nuclear power

By 2030, the installed capacity in the renewable energy sector is expected to grow by nearly 200% compared to 2023.

Renewable energy must replace coal-based energy, which is associated with high emissions and declining profitability.

mapa pl

Wind power in Poland

The Polish wind energy market is experiencing dynamic growth, and forecasts indicate this trend will continue. The year 2025 brings positive legislative developments, including the liberalization of the Wind Turbine Act and new regulations supporting the development of offshore wind projects in the Baltic Sea. By 2030, Poland aims to reach 5.9 GW of offshore installed capacity and 18 GW by 2040.

Despite the optimism, the sector still faces significant challenges, including the expansion and modernization of transmission networks, investments in energy storage, and balancing power sources.The goal is to achieve 30 GW of installed wind capacity by 2030, paving the way for decarbonization and transformation of Poland’s energy mix.

wind farm

Solar power in Poland

Poland has strengthened its position in the energy market, particularly in the solar sector, which accounted for nearly 63% of the total installed RES capacity in 2024.
As of December 2024, the installed PV capacity stood at 21.2 GW.

It is projected that by 2030, Poland will reach 29 GW of solar power capacity, placing the country among the EU leaders in both installed capacity and electricity production from solar panels.

solar

How can we help?

We assist foreign investors in entering the Polish RES market, offering end-to-end advisory services, including the selection of the optimal legal and tax structure, business registration, obtaining required permits, and structuring projects in line with applicable regulations.

 We support clients at every stage of their operations, providing practical solutions tailored to the specifics of their business. We offer comprehensive 360° advisory services – tax, legal, and accounting – ensuring compliance and cost efficiency.

We support asset and project company transactions, including acquisitions and disposals. Our team advises on transaction structuring and conducts due diligence processes, identifying key risks and safeguarding investments.
CIT
Piotr Pasko kwadrat
Piotr Paśko

Partner | Tax Adviser
E: piotr.pasko@mddp.pl
T: +48 602 197 893

  • Choosing the optimal legal form – we provide end-to-end support in selecting the optimal legal structure for RES businesses and assist clients in building an appropriate corporate structure.
  • Investment preparation and development – we offer support throughout the investment and construction process, including the determination of initial asset value / cost segregation. We provide advise on the allocation of acquisition costs, as well as tax depreciation, real estate tax, and bookkeeping. Our services also cover investment implementation, including financing strategies, risk analysis, and business planning.
  • Tax reviews – we conduct analyses of the methodology for reconciling accounting and tax results, verify the accuracy of income and cost recognition, and assist in reviewing tax settlements (including in connection with plans for new investor entry).
  • Transactions – we provide end-to-end transaction advisory services, including both share deals and asset deals. Our support includes conducting due diligence for planned acquisitions and exit strategies. We actively participate in negotiations and review transaction documentation.
  • Withholding tax (WHT) – we provide comprehensive advice on planned profit distributions, assessing tax liability and the correct application of withholding tax, including exemptions available to foreign investment funds (e.g., SICAV, RAIF). We analyse eligibility for WHT exemptions and conduct audits of the beneficial owner’s actual business activity of payment recipients. We also handle refund procedures and applications for opinions on the application of preferential tax treatment.
  • Restructuring – we offer full-scope advisory services for mergers, demergers and transformations, including cross-border operations – also in connection with planned transactions. We advise on contributions in-kind, share exchanges, and liquidations, including in light of upcoming regulatory changes.
Transfer Pricing
Adrian Mroziewski kwadrat
Adrian Mroziewski

Partner
E: adrian.mroziewski@mddp.pl
T: +48 505 294 041

  • Comprehensive TP consulting in the area of determining the settlement structure of RES projects within capital groups – we provide tax advisory services covering the determination of arm’s length remuneration for financing, implementation, and maintenance of RES projects, ensuring optimal intra-group settlement security.
  • Implementation TP reporting obligations (TP Compliance) – we prepare all legally required transfer pricing documentation (local file, master file), including benchmarking and compliance analyses, as well as transfer pricing information forms (TPR-C, TPR-P).
Tax reliefs
Bartosz Glowacki
Bartosz Głowacki

Partner | Tax Adviser
E: bartosz.glowacki@mddp.pl
T: +48 603 980 382

  • Tax reliefs (R&D relief, relief for innovative employees, activity in the Polish Investment Zone, relief for CSR) – we analyze options for applying reliefs in income taxes, help implement reliefs in the company and assist in their settlement
Real estate tax and cost segregation
Rafal Kran kwadrat
Rafał Kran

Partner | Tax Adviser
E: rafal.kran@mddp.pl
T: +48 693 290 919

  • Cost Segregation – we provide services to account for CapEx of RES investments on fixed assets (tax and balance sheet depreciation) and for determining the optimal real estate tax base
  • Tax proceedings – we handle taxpayers’ disputes and overpayment cases with municipal authorities regarding real estate tax settlements (e.g. regarding the correct tax rate or tax base)
VAT
Janina Fornalik
Janina Fornalik

Partner | Tax Adviser
E: janina.fornalik@mddp.pl
T: +48 660 440 141

  • Ongoing consulting – comprehensive VAT consulting at every stage of the renewable energy production business, including the acquisition and sale of assets and companies.
  • Transaction advisory in the RES industry – assisting investors in transactions like the sale or purchase of real estate, shares in companies or service contracts.
  • Advising on the settlement of contracts – investment (TSA, PMSA, turnkey contract) and electricity sales (PPA and vPPA).
  • Assistance in obtaining VAT refunds for SPVs.
  • Advice on structuring transactions within a group of companies for VAT purposes – e.g. using the option to opt for taxation of financial services, forming a VAT group.
  • Implementing the National Electronic System (KSEF) – we help clients implement KSEF to support easier and more efficient operations and ensure compliance with government requirements.
Excise duty
Agnieszka Kisielewska
Agnieszka Kisielewska

Partner | Tax Adviser
E: agnieszka.kisielewska@mddp.pl
T: +48 600 097 363

  • Ongoing excise consulting – at the pre-operational and operational stages within the RES business.
  • Excise duty obligations – assistance in determining excise duties related to the production and consumption and/or sale of electricity produced from RES by businesses, individuals and local government units.
  • Excise duty exemptions – we confirm the applicability of excise exemptions within the RES business and assist in their implementation.
  • CRPA registration – support in registration in the Central Register of Excise Entities (CRPA), e.g. in connection with the implementation of obligations related to the production of energy from renewable sources.
  • Keeping excise duty records – support in implementing excise duty records, including within the framework of the Central Excise Product Register (CEWA).
Corporate law
  • Selecting the optimal legal form – comprehensive support in choosing the optimal legal form for an RES enterprise, tailored to the individual characteristics of an investor.
  • Company registration – we prepare all corporate documents necessary to start a business in Poland and we represent our clients before the relevant registries.

#MORE on Osborne Clarke website: link
Green energy funding
  • Handling financing transactions – our team of lawyers specialized in banking and energy comprehensively supports clients during the process of obtaining external financing. As the project advances, we supervise the fulfillment of conditions precedent and consequential conditions of the RES investment financing contracts.

#MORE on Osborne Clarke website: link
Energy sector
  • RSE transaction advisory – we support clients in renewable energy investments and transactions, offering financial advice, risk and business strategy analysis.
  • Comprehensive due diligence for RES projects – we assist in the process of verifying project documentation for photovoltaic power plants, wind power plants, biogas plants and electricity storage facilities.
  • Energy contract advice (PPA, CPPA, VPPA) – we provide comprehensive support to green energy generators and consumers, also in the field of guarantees of origin.
  • Advice on generating green energy for own use – we support energy consumers in the construction of generation sources and effective management of electricity.
  • Energy efficiency improvement consulting – we help identify areas to introduce pro-efficiency solutions and develop energy strategies for enterprises.

#MORE on Osborne Clarke website: link
Labor law
  • Hiring employees or associates in Poland – we assist in drafting various types of contracts. We also provide the necessary documentation related to employment and assist in fulfilling the employer’s obligations.
  • Hiring foreigners in Poland – we advise on the process of posting employees: from Poland to other countries and from abroad to Poland. We assist in legalization of work and stay of foreigners.
  • Incentive schemes, bonus and benefit systems – we support developing incentive schemes and fringe benefit plans that contribute to greater employee loyalty and satisfaction. We prepare internal regulations for bonus and benefit systems.
  • We support the creation of organizations free from irregularities – we help create workplaces free from discrimination and mobbing.

#MORE on Osborne Clarke website: link
CIT and VAT
  • Certificates of origin – we guarantee our clients receive accounting services tailored to the specifics of taxation as we are perfectly familiar with the regulations in this area and their specific nature.
  • VAT refunds – we help our clients with VAT refunds, especially with increased capital expenditures at the beginning of the business.
Warehouse accounting services
  • Inventory records – we provide comprehensive maintenance of inventory records and determination of the correct value of current assets related to inventory management for RES businesses.
Cost optimization
  • Cost accounting – regardless of the investment stage, we propose to our clients to recognize costs in such a way so that later it is easier to go through the process of acceptance of fixed assets and settlement of the external financing itself, or group financing. 
Bookkeeping records
  • Bookkeeping records – we support clients in bookkeeping by offering a comprehensive full accounting service. Our team keeps clear accounting records and proper documentation of transactions considering the specifics of the industry. We understand the legal regulations in the area of RES involve certain specificities regarding the recognition of accounting transactions related to certificates of origin of electricity. Polish accounting and tax regulations do not feature specific solutions relating to certificates of origin as a specific element of the activities of energy companies. Instead, knowledge of tax topics should come from the case-law that has been formed over time in this matter.  
Proceedings related to property tax and property rights trading
  • Recording of property rights – we provide comprehensive bookkeeping, considering issues related to the correct recording of property rights arising from certificates of origin of electricity. Our team knows how to correctly recognize property rights arising from certificates of origin of electricity from the side of enterprises producing RES.
Energy law-based reporting
  • RES reporting – we prepare reports and ensure reporting for companies, and we also prepare consolidated financial statements. We also support our clients in compiling reporting templates. We have tools to prepare consolidated data quickly and accurately. In addition, our dedicated reporting team provides substantive support to our clients and adjusts systems and reports also to reflect changes in the capital group.
magdalena michniewicz senior manager.jpg
Magdalena Michniewicz

Partner
E: magdalena.michniewicz@mddp-outsourcing.pl
T: +48 502 413 975

michal stanioszczyk accounting manager.jpg
Michał Stanioszczyk

Accounting Director
E: michal.stanioszczyk@mddp-outsourcing.pl
T: +48 518 094 501

agnieszka tyczynska osinska senior accounting manager.jpg
Agnieszka Tyczyńska-Osińska

Senior Manager
E: agnieszka.tyczynska@mddp-outsourcing.pl
T: +48 504 120 116