Cezary Przygodzki specializes in corporate tax issues for key sectors, including in particular energy, TMT and real estate clients. He also has a great track record in advising financial institutions and private equity clients. His outstanding scope of experience covers international tax planning, M&A tax structuring, business restructuring and reorganization, fund structuring, assistance with foreign investments in Poland, including grants and tax incentives in special economic zones as well as comprehensive tax reviews and audits.
Cezary has taken part in numerous conferences and courses in Poland and abroad as both a participant and a lecturer. He works on a regular basis with chambers of commerce as a tax expert. He has authored numerous articles on Polish and international tax law in technical periodicals and business dailies.
- Advising on customs and tax aspects related to construction and functioning of the first Crude Terminal in Gdansk, Poland. Worth €200 million, the investment is of strategic importance for Poland and its goal to diversify its crude oil supplies.
- Advising on international tax structuring project for a global manufacturing firm. One of the first structures on the Polish market involving a Luxembourg based partnership (SCSp) and a Polish investment fund.
- Advising on a €2.2 billion investment in new energy units in Opole power plant, including establishment of a new operating model for the consortium and key subcontractors building two new coal-fired units in Opole power plant. This is the largest single conventional energy project in Poland and this part of Europe.
- Advising on parallel, multibillion, multiannual projects on development of oil and gas deposits in the Baltic Sea. This assignment covered review and recommendations of various structuring options, tax assistance with setting up of the SPVs for particular projects, available asset contribution and step-up scenarios, support with negotiations of tax matters with the joint venture partners and revision of the respective agreements, involvement in tax ruling procedures, adjustment of the investment plans to the on-going legislative developments, compliance advice in interaction with regulatory and mining regulations, as well as setting out of tax aspects in the documentation which affected the banks and investors.
- Advising on the takeover of the SwePol Link, a submarine cable, by Polish and Swedish transmission grid operators. The tax support included the comprehensive tax structuring of the transaction, including cross-border tax aspects and cooperation with Swedish and Danish tax lawyers, carrying out a tax due diligence review, participation in negotiations on tax matters and providing tax security of the transaction for our client by obtaining tax rulings from the Polish tax authorities.
- Advising on tax aspects connected with restructuring of a €1 billion portfolio of loans given to a Polish subsidiary.
- Advising on tax planning and restructuring connected with IP management, including cross-border considerations. The tax services comprised comprehensive tax structuring of the transaction, including selection of the IP holding jurisdiction, financial modeling of the transaction, preparation of relevant agreements and securing the tax security of the transaction for our client through obtaining tax rulings in various jurisdictions. The tax effective IP structure was the key outcome of the project. Value of the transaction: €170 million.
- Advising on Polish tax aspects associated with taking up and issuance of a hybrid debt instrument. Value of the instrument: $200 million.
- Advising on the sale and takeover of a public company listed on the Warsaw Stock Exchange. Value of the transaction: €70 million.
- Advising on the restructuring of a Polish internet group and its operations in a tax effective way. Value of the transaction: €100 million.
- Assisting a client in setting up a production facility in a Special Economic Zone in Poland, including negotiations with the Ministry of Economy (it was a precedent-setting transaction as for the first time in history the investor made use of the terms and conditions established for a previous investor).
Activities and Affiliations
- Board Member - Mazovia Branch of the Polish Chamber of Tax Advisers (2010-2014)
Prior and Present Employment
- Partner - Dentons (formerly Salans), Warsaw (2012 to date)
- Counsel - Salans, Warsaw (2009-2011)
- Senior Tax Manager - Ernst & Young, Warsaw (2008-2009)
- Tax Manager - Ernst & Young, Warsaw (2005-2008)
- Tax Consultant - Andersen / Ernst & Young, Warsaw (2001-2005)