The highest standards
  • High quality services, standards comparable for international consultancy companies
  • Comprehensive services
The highest standards
  • High quality services, standards comparable for international consultancy companies
  • Comprehensive services
The scope of our support

  • The greatest experience and recognition on the excise tax advisory market.
  • Effective resolution of disputes and obtaining permits.

Parulski & Wspólnicy Doradcy Podatkowi is a renowned team of high-class excise and customs duties specialists. We deal with the toughest and most precedent-setting cases; we are found where other advisors do not have the knowledge, experience or even the courage to act!

Our almost twenty years of experience in and comprehensive insight into all issues related to indirect taxes (VAT, excise and customs duties) ensure that we efficiently present solutions covering all aspects of the taxation of international commodity transactions and complex production issues that occur in industry.

We do not provide tax advice on common matters appropriate for accounting offices or general tax advisors. We do not operate in the field of CIT or PIT statements; we do not provide assistance to our Clients in TP- or JPK-related matters. In fact, we leave these areas to other specialists in these fields.

We are quick and precise in presenting the situation. We clearly communicate to our Clients not to execute a given transaction or not to continue a dispute with the tax authorities where we do not see a chance of success. However, before we say so, we present all possible options, including non-standard actions, that go beyond the common practice of tax and legal advice.

First of all, we want to resolve any possible doubts at the earliest stage possible. We do not wait for the decisions of the tax authority – we actively present our arguments by talking to the officials. Wherever possible, we do it on a partnership basis; where employees and officers are not interested in the discussion,  we run the proceedings with determination by conducting all evidentiary activities so that the case is won at the earliest stage possible. We are aware that the appeal procedure in taxes does not exist in practice, and the judicial decisions of administrative courts are at best a lottery.

Only a consistent approach to the problem and the handling of the case to the end allow for the development of partnership relations with the tax authorities. However, sometimes more decisive actions are needed; these include complaints to the European Commission. Our positive experience in this area means that such actions require time and resources, but only such actions yield long-term results in the most important cases.

Formula of Cooperation

We are independent, and it makes us flexible when working with Clients. We are ready to cooperate on their preferred principles. We do not aim at creating theoretical opinions or reports; we want to solve problems quickly and effectively. Therefore, we are ready to comprehensively analyze a specific issue and present it at a meeting accompanied by a concise presentation or summary including conclusions from the analysis.

However, when our Clients expect a comprehensive presentation of a given issue in writing, we are eager to prepare opinions and detailed reports (e.g. reports summarizing tax audits, regulatory reports and indicating the perception of a given issue in the national and international context) as we are experienced in the above. Our opinions and reports are always aimed at presenting clear conclusions and recommendations based on all available legal arguments, the practice of their application by tax authorities and other taxpayers, as well as the case law of courts, including the EU Court of Justice. Wherever possible, we do our best to avoid understatements and present a range of possibilities for our Clients’ decisions.


Besides the complexity of tax issues (mainly VAT and excise), there are also important obligations under customs law for trade in goods with non-EU countries.

The specificity of customs regulations and the practice of customs authorities makes the mere knowledge of regulations insufficient for the proper execution of transactions. It is also necessary to have hands-on experience in applying customs regulations. Possible irregularities related to the failure to adapt the business to the customs regulations may not only involve the obligation to pay customs duties with interest, but may also significantly hinder the exchange of goods (e.g. by delaying the delivery or increasing transaction costs).

Below we present the areas in which, as experienced advisors, we are willing to assist entrepreneurs operating on the Polish market. Apart from assistance concerning current or planned transactions, our experience in implementing effective structures of goods trade allows us to efficiently and effectively verify the correct application of customs regulations. On the one hand, such verification makes it possible to identify and neutralize the identified risks at an early stage, while on the other hand, it very often results in an increase in the effectiveness of transactions (by reducing theamount of customs charges or by streamlining and reducing the costs related to the trade of goods).

As tax advisors, we are authorized to represent entrepreneurs at all levels of customs proceedings, including proceedings before the Voivodship Administrative Courts and the Supreme Administrative Court.

Customs Advice – Our Services:

Our assistance in the field of customs regulations may include, but is not limited to:

  • assistance and advice on applying for customs permits and statuses (including permits for special procedures, including processing, customs warehousing, transit, simplified procedures, including authorized consignee and authorized consignor, AEO)
  • assistance and advice on the effective application of customs procedures
  • assistance in the process of obtaining Binding Tariff Information
  • assistance in obtaining Binding Origin Information
  • verification of the regularity of the goods classification (CN)
  • verification of the regularity of the customs value calculation
  • analysis of the regularity of determining the origin of goods for the purpose of applying preferential tariff measures
  • representation of entrepreneurs during customs inspections or customs proceedings before the Head of the Customs and Fiscal Office, in appeal proceedings before the Director of the Fiscal Administration Chamber and in court-administrative proceedings before the Provincial Administrative Court or the Supreme Administrative Court in all matters related to customs regulations
  • training of employees involved in international trade of goods
  • advice on other legal regulations affecting international trade in goods
  • ongoing advice on the application of customs regulations and tax consequences related to international trade in goods

Formula of Cooperation

We are independent, and it makes us flexible when working with Clients. We are ready to cooperate on their preferred principles. We do not aim at creating theoretical opinions or reports; we want to solve problems quickly and effectively. Therefore, we are ready to comprehensively analyze a specific issue and present it at a meeting accompanied by a concise presentation or summary including conclusions from the analysis.

We know the mentality of customs officers, and this allows us to obtain all necessary customs permits more efficiently and effectively. Where necessary, we are ready to be more assertive than our clients, who work with the Customs and Fiscal Service on an everyday basis. We don’t fight over details; we just want to get things done smoothly.

We are the precursors of regulatory advice commonly called lobbying. Our advice in this area is of an expert nature. We convince the legislator with the strength of substantive arguments, not of contacts or connections. Since the beginning of our activity, we have been included in the list of entities providing lobbying services. However, we are not limited to national regulations; we have effectively represented entities and industry organizations in the course of work on amendments to EU excise directives or customs regulations.

Depending on your needs and possibilities, our regulatory advisory services may include:

  • issuing opinions on draft laws and regulations at the stage of the Ministry of Finance (or other ministries)
  • active participation in Conciliation Conferences at the MF as part of public consultations
  • participation and representation during the work phase in parliamentary and senate committees
  • analysis and preparation of postulates for changes in tax regulations addressed to the Ministry of Finance
  • preparation of regulatory reports of an industry or cross-cutting nature
  • issuing opinions and participation in consultations on amendments to EU excise directives at the level of the European Commission
  • comprehensive assistance in the process of changing EU and global customs regulations, with particular emphasis on the EU Customs Tariff and the Harmonised System (HS).

Our Experience – Our Reports:

Excise Duty Deregulation – 2013 

In the framework of this project, we compiled a number of problems faced by the largest taxpayers in the fuel, chemical, alcohol and tobacco industries. Then, together with the taxpayers from these industries, we prepared and presented to the MF a comprehensive package of solutions, which the Ministry subsequently adopted as its own project. We are aware that not all ideas could be accepted, and we had to wait a few years for a part of them to be completed. Now, however, after more than 7 years from the presentation of the report, we know that patience pays off as more than 60% of the postulates prepared by us have become a law that allows for safer and easier excise activities on a daily basis.

Tariff and Excise Classification of Fermented Drinks

The disputes we handle with the tax and customs authorities often concern the majority of taxpayers in a given industry. This was the case with fermented beverages, commonly called fruit wines. The historic bad reputation of these products was facilitated by a frontal attack of the customs administration in Poland. To show that the position of the customs authorities and the Ministry of Finance in this respect was not only incorrect but also biased, we prepared a report in which we compared the jurisprudence practice of the customs authorities in Poland and other EU countries. We were not afraid to refer this report to the European Commission, which was surprised that Polish businessmen were seeking help against the temptations of their fiscal authorities. Such a strategy was fruitful not only because of the fact that the conducted disputes were successful in Poland, but also because our report was included in the periodic evaluation of the practice of applying EU excise regulations in the EU.

Effective Fight against the Grey Zone in Excise Duty

Fighting the grey market requires not only operational skills, but also knowledge of the excise industry, so that the proposed solutions do not hinder the activities of lawfully operating entities. Our experience in supporting the producers of tobacco products, alcoholic beverages and fuels has allowed for the presentation of a number of concepts that have so far been unknown or disapproved of in Poland. We managed to persuade the Ministry of Finance to allow for the electronization of trade of products exempt from excise duty (e-DD) or SENT road monitoring. We are aware that not there are still goals to be accomplished, and the Ministry of Finance still hasn’t compensated honest taxpayers for the effort. However, we believe that such a situation is not everlasting, and preferences are possible for those who are honest and reliable and not just the biggest ones in the industry.

Innovative Tax Solutions in Excise Duty

We can say that tax advisors should not get involved in the rates of excise duty or taxation of new categories of goods. However, where the existing regulations caused economic anomalies or even product formulas were created to take advantage of specific preferences (lower rates) of excise duty, we considered it our duty to challenge and present new, better taxation models. This is particularly true of the alcohol industry, but it may also be the case of the tobacco industry or even the highly nationalized fuel industry. Our analysis completed with the regulatory report has not yet been reflected in the regulations, but the Ministry of Finance has already made several attempts to implement our proposed solutions, such as the tax on carbonated beverages or dietary supplements. We believe that it is better to introduce new selective taxes than to increase the already high excise duty rates on traditional excise goods.

Formula of Cooperation

We provide regulatory advisory services to industry organizations (employers’ associations, associations) as well as to individual taxpayers for whom a draft law or regulation in force needs to be amended for any purpose or reasons. Depending on the purpose and complexity of the issue, our assistance may be either comprehensive or ad hoc. We are open to lead the entire regulatory project from beginning to end, but also to participate in its selected part (to prepare a draft amendment to the regulations or to represent a specific entity at departmental consultations or parliamentary works).


The number of strong links between tax regulations and other areas of law is becoming increasingly frequent. We firmly believe that our good ideas can be applied to SENT and quasi-tax fees. Regulations that impose additional charges on goods already taxed are equally dynamic in the legal system.

Tax and non-tax regulations are often intertwined in a tangle of regulations that leaves not only entrepreneurs but also lawyers easily lost. Such a situation is particularly visible as regards the movements of raw materials and finished products being excise goods.

For this reason, to meet the expectations of our Clients, we have decided to expand our business activity by offering assistance also in the performance of obligations indirectly related to taxes.

We will be pleased to accept challenges concerning:

  • the system for monitoring the transport of goods SENT
  • fuel, emission, backup charges
  • the tariff classification of goods for non-tax purposes and industry regulations
  • sugar duty and „monkeys” fee.

We are eager to assist our Clients in difficult issues of SENT and other fees by sharing our experience with them.

Thanks to our experience in cooperation with a number of industries, we have been able to explore the specificity of the fuel, chemical, energy or alcohol industry, as well as tobacco, including e-cigarettes and innovative products. Hence, where such synergy takes place, we are ready to assist our Clients in legal issues. Wherever there is such a need, we have no fear of consulting our ideas and solutions with experienced lawyers in a relevant branch of law; we know that industrial experience does not do the entire trick, which is why we provide supervision of experienced legal advisors or advocates as part of our assistance.

We specialize in matters concerning:

  • administrative law
  • non-tax charges
  • regulatory advice in the area of the broadly defined control of business activity.

Our experience and knowledge allow us to assist you in many areas of administrative law, which are little known and hermetic to other advisors or even lawyers. We have successfully advised, for instance, on matters involving:

  • regulations concerning mandatory stocks of petrochemical products,
  • the provisions relating to mandatory gas stocks,
  • energy efficiency regulations.
  • energy law regulations,
  • regulations concerning fuel quality and regulations on biofuels,
  • regulation of business licensing in many industrial and commercial sectors,
  • provisions on import and export restrictions,
  • and many other areas of Polish legal regulations.

Our pragmatic approach is one of our hallmarks. We provide our Clients with practical solutions that allow them to operate in the maze of regulations and to solve their problems quickly.