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Marek Kozaczuk

Marek Kozaczuk focuses his practice on tax law, with an emphasis on mergers and acquisitions, corporate restructuring, tax controversy and litigation.

Concentrations

  • Mergers and acquisitions
  • Tax controversy
  • Corporate restructuring

Capabilities

Experience

  • 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 at 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. 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 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 repayment 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.°
  • Represented a listed company before tax authorities in connection with recharacterizing an underwriting agreement into a loan.°
  • 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 power producer before tax authorities and administrative courts in connection with the correction of 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 advertisement 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 Grzesiak sp.k.

Recognition & Leadership

  • Chambers Europe: Band 2 in Tax, 2015-2020, Band 3 in Tax, 2011-2014
  • EMEA Legal 500: leading individual in Tax, 2013-2020
  • Legal 500 Hall of Fame: honored in Tax, 2018-2019
  • Chambers Global: Band 2 in Tax, 2015, Band 3 in Tax, 2011-2014
  • Best Lawyers: recommended in Tax, since 2010
  • Member, Warsaw Bar Association of Attorneys-at-Law, Poland
  • Member, National Chamber of Tax Advisors, Poland

Credentials

Education
  • Tax Advisor, 2005
  • Attorney-at-Law, 2002
  • Master of Law, Warsaw University, 1997
Admissions
  • Poland
~ Certain partners in Greenberg Traurig Grzesiak sp.k. are also shareholders in Greenberg Traurig, P.A.
Languages
  • Polish, Native
  • English, Fluent