No names, no photographs. Situation, complication, what we did, outcome — the way the work actually runs.
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Banking partner:
Santander Bank Polska
Registered in the UAE as
SoCap City LLC-FZ
Court of Appeal ruling - PIP inspected -
MF position in EUREKA
Client held a Polish entity and intended to build a payments business on a third-party whitelabel.
The plan was to serve clients under someone else’s licence. That is unlicensedactivity, not an arrangement.
Stopped the build before launch and set out the licensing route the model actuallyrequires.
The client did not begin operating without authorisation.
A Polish company was about to pay a foreign service provider under an ongoing contract.
Paying an individual triggers 19% withholding tax on the payer’s side plus 23% VAT— 42% of the payment value.
Restructured the contract so the counterparty invoiced through a legal entity, moving VAT to reverse charge with no withholding due.
42% retained on every payment under the contract, not once
Client moved goods bought in the EU onward to a third country and had correctlyidentified the customs procedure that removes import VAT.
The rule was right. The execution was not — 23% was assessed at the border,because the carrier had not agreed to operate under the procedure and thedocuments were not in place beforehand.
Recovered the VAT already paid. For the next shipment we selected a logisticsoperator willing to work under the procedure and prepared the full document set inadvance.
No VAT at the border on subsequent shipments. The procedure now runs asstandard for this client.
Bring us the structure you have in mind — we will tell you what it takesand where the complications hide.
