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Marek Kozaczuk is an experienced tax and legal advisor with almost 30 years' experience in tax advisory services. He specialises in preventing and resolving tax disputes, and in providing transaction and ongoing tax consultancy. He has particular expertise in the taxation of foreign-controlled entities, mergers, divisions and transformations.

His advisory services include tax risk assessment, dispute prevention, tax and customs proceedings, social security matters, tax refunds, and defence in criminal tax cases (including the personal liability of management board members), as well tax transaction advisory services, in particular relating to mergers, divisions and transformations. He also has extensive experience in working with companies in the IT industry.

Marek has represented clients before tax, customs and social security authorities, as well as administrative courts, the Supreme Administrative Court, the Supreme Court and the Constitutional Tribunal. He has handled over 1,000 cases during his career.

Marek's clients include some of the most recognised names in business: AIG Bank, Anastasia Beverly Hills, Animex, Asseco Poland, Budimex, CEDC, CD Projekt, Coca-Cola, Emperia Holding, Expander Advisors (Allianz Group), Madison Real Estate, Mars Corporation, Millennium Leasing and PGE Energia Odnawialna.

Concentrations

  • Mergers and acquisitions
  • Tax controversy
  • Corporate restructuring

取扱分野

実績紹介

  • Represented the group of founders of Univio, in connection with the tax aspects of the sale of a majority stake in the company to Value4Capital.
  • Represented Velo Bank and Cerberus in connection with the tax aspects of the PLN 1.1 billion acquisition of Bank Handlowy’s consumer business in Poland.
  • Represented insurance companies from the UNIQA Group in connection with the tax implications of the conclusion of strategic 12-year cooperation agreements with mBank for the distribution of insurance products.
  • Represented ISOC Group, a Manila-based (Philippines) investor, in connection with the tax aspects of the acquisition of the Argon building in the Alchemia office complex in Gdansk. 
  • Represented Deutsche Bank AG in connection with the tax aspects of the sale of its Polish Private and Commercial Bank business to Santander Bank Polska.
  • Represented BNP Paribas Group in connection with the tax aspects of the acquisition of the core banking business of Raiffeisen Bank Polska S.A. by Bank BGŻ BNP Paribas S.A. 
  • Represented Société Générale in connection with the tax aspects of the sale of Euro Bank, its retail banking subsidiary in Poland, to Bank Millennium.
  • Represented KGAL Investment Management in connection with the tax aspects of the acquisition of Spark C, a 10-story office building located in Warsaw’s Wola district.
  • Represented Alior Bank in an agreement to acquire Bank BPH’s core business from affiliates of GE Capital.
  • Represented PKO BP Bank in the acquisition of Nordea Bank Poland, Nordea Life and Nordea Finance. The value of the transaction was approx. PLN 3.5 billion.
  • Represented Budimex S.A. in connection with the sale of Budimex Danwood sp. z o.o. The value of the transaction was PLN 238 million.
  • Represented Polski Bank Przedsiębiorczości S.A. and FM Bank S.A. in the merger of both banks within the Abris Capital Group.
  • Represented Polkomtel sp. z o.o. on the reverse merger with Spartan Capital Holdings, which was the last phase of LBO structure implementation. The value of the transaction was EUR 4.5 billion.
  • Represented the Joint Global Coordinators: Citigroup Global Markets Limited, DMBH, Société Générale, UBS and Deutsche Bank AG, London Branch, and the Joint Bookrunners: DM PKO BP, DI BRE, DM BZ WBK and Wood&Co in the PLN 238.6 million IPO of Polski Holding Nieruchomości (PHN). 
  • Represented Spartan Capital Holdings in LBO financing for the acquisition of Polkomtel and the development of an LTE network.°
  • Represented Cyfrowy Polsat S.A. in connection with obtaining financing for the acquisition of Telewizja Polsat S.A.°
  • Represented AIG in tax issues with respect to the merger of its Polish consumer finance business into Santander’s Polish bank.°
  • Advised PZU S.A. on reaching a settlement between its shareholders, the Polish State Treasury and Eureko, concerning the control of the company.°
  • Advised and represented Coca-Cola HBC Polska sp. z o.o. in matters relating to the interpretation of VAT regulations and an excise tax refund.°
  • Advised and represented Wrigley Poland sp. z o.o. before customs authorities, administrative courts and the Constitutional Tribunal with regard to customs duty.°
  • Advised real estate investors in Poland on optimizing VAT and CIT.°
  • Represented a Polish company from the FMCG sector before tax authorities, customs authorities and administrative courts in cases related to VAT on advertisement and promotion, tariff classification of odoriferous substances and excise tax imposed upon importation of such substances.°
  • Represented IT companies before tax authorities and administrative courts in cases related to the refund of taxes (WHT) paid in Poland on foreign software license fees.°
  • Represented Polish companies from the pharmaceutical sector before customs authorities, tax authorities and administrative courts in cases related to CIT, VAT and customs duties.°
  • Represented a listed company before tax authorities in connection with recharacterizing an underwriting agreement as a loan agreement.°
  • Represented an international bank before tax authorities in connection with recognizing credits and loans classified as doubtful as tax deductible costs.°
  • Represented a Polish green energy producer before tax authorities and administrative courts in connection with the correction of the tax depreciation of fixed assets contributed in kind.°
  • Represented a company from the media sector before customs authorities and administrative courts in connection with the exemption of advertising materials from customs duty.°
  • Advised a European gypsum board manufacturer on tax issues related to restructuring of its joint venture with a Polish manufacturer of construction materials.°
  • Represented a Polish life science company before tax authorities in cases related to VAT on a pharmaceutical manufacturing license agreement and regulated prices of pharmaceuticals.°
  • Advised on mergers of Polish companies, including banks.°

°The above representations were handled by Mr. Kozaczuk prior to his joining GREENBERG TRAURIG Nowakowska-Zimoch Wysokiński sp.k.

受賞歴・所属団体

  •  Chambers Europe: 
    • Band 2 in Tax (2015-2025)
    • Band 3 in Tax (2011-2014)
  • EMEA Legal 500: 
    • Hall of Fame in Tax (2018-2019, 2021-2025)
    • Leading Individual in Tax (2013-2020)
  • ITR World Tax: Notable Practitioner in Tax (2023-2026)
  • Lexology (WWL): Recommended Lawyer in the 2025 Lexology Index: Tax – Advisory Practice Area Report
  • Best Lawyers: Recommended in Tax (since 2010)
  • Member, Warsaw Bar Association of Attorneys-at-Law, Poland
  • Member, National Chamber of Tax Advisors, Poland

学歴・資格・言語

学歴
  • Tax Advisor, 2005
  • Attorney-at-Law, 2002
  • Master of Law, Warsaw University
弁護士資格
  • Poland
~ Certain partners in GREENBERG TRAURIG Nowakowska-Zimoch Wysokiński sp.k. are also shareholders in Greenberg Traurig, P.A.
言語
  • Polish, Native
  • 英語, Fluent

Related Capabilities

Tax コーポレート リストラクチャリング&インソルベンシー