Michal Maj

Michał Maj

Counsel
Baker McKenzie Krzyżowski i Wspólnicy Spółka Komandytowa

Biography

Michał Maj has over 11 years of experience in tax advisory services with a particular focus on M&A. Michał started his career in 2007 in KPMG and has worked in PwC since 2009. Michał provides advice on the tax effective structuring and acquisition transactions. He has been involved in numerous due diligence projects (including vendor due diligence) related to the acquisitions of Polish business entities. Michał's specialization also includes tax restructuring of business entities for the realization of unique business aims. He was involved in cooperation with private equity funds, multinational corporate clients as well as Polish firms and individuals. In addition, Michał supports clients during tax audits and further proceedings, including proceedings before the court.

Michał has been a licensed Polish tax advisor (license no. 11530) since 2010.

Practice Focus

Michał's practice focuses on tax structuring, tax due diligence, general tax advice, management incentive plans and tax litigation. He has advised private equity clients, local and multinational corporations and Polish individuals in the energy, FMCG, media, real estate and retail sectors.

He has experience in the jurisdictions of Poland, Luxembourg and the Netherlands.

Representative Legal Matters

  • Advised on vendor tax due diligence for a group of over 15 companies of one of the biggest energy players in Poland — PGE Group — for the purposes of IPO/EDF regarding an exit from Poland. 

  • Advised on tax due diligence for a shopping center operator plus tax structuring (involving closed investment fund) for Inter IKEA Center Poland.

  • Advised on the set-up of a closed investment fund for one of the US clients and on the transfer of the group structure under the fund.

  • Advised on the set-up of a Luxembourg investment structure (project led by Polish team) for one of the investment funds.

  • Advised on tax due diligence for a number of SPVs operating in the real estate sector (commercial buildings) for a new investor, including tax structuring (from a share deal into an asset deal) — Technopolis Group.

  • Advised on tax due diligence for one of the biggest retail chains in Poland for a PE house (one of the biggest transactions on the Polish market in last years) — for CVC over Żabka/for Bridgepoint over Smyk.

  • Advised on the tax structuring (development of the structuring ideas and implementation) of a joint venture of the key two players from TV/media sector in Poland for TVN.

  • Advised on tax structuring (including assistance for the management) on one of the biggest exits of a private equity fund from investment in Poland — for Monatgu on exit from Emitel.

  • Advised on vendor tax due diligence support for a private equity fund on the exit from a Polish investment in a chain of private medical and diagnostic centers — for MEP over Lux Med.

  • Advised on tax structuring (and assistance during the implementation) of a separation of part of a business and its transfer in a tax efficient manner to a new investor for one of the biggest producers in Poland — for Grupa Żywiec on joint-venture with Orbico. 

  • Advised on sell-side structuring and provided support for individuals on their exit from business in Poland.

  • Advised on tax structuring on the refinancing of euro-bonds for one of the biggest corporations in Poland.

  • Advised on a number or tax litigations concerning past restructurings.

Admissions

  • Poland (2010)

Languages

  • English
  • Polish
  • Co-author, "Financing of acquisition transactions - tax aspects" / Finansowanie transakcji - aspekty podatkowe - PwC Tax M&A Report, April 2015
  • Co-author, "Current Challenges Facing Retail Sector - or how to effectively implement the on-line sales channel for a conventional shop" / "Aktualne wyzwania dla handlu detalicznego czyli jak skutecznie wprowadzić elektroniczny kanał sprzedaży w tradycyjnym sklepie?" - PwC Report on E-commerce market, 2011
  • Co-author, "Increase of the purchase price of an intangible assets as a result of earn-out" / "Zwiększenie ceny nabycia wartości niematerialnych i prawnych na skutek ziszczenia się dodatkowego warunku", Taxonline, 2012
  • Co-author, "Acquisition of clients list/base - moment of recognition of tax costs" / Wydatki na nabycie bazy danych klientów - moment rozpoznania kosztów uzyskania przychodu, Taxonline, 2011, 
  • Presenter, "Leasing for entrepreneurs - tax aspects" / "Leasing w firmie" - TVN CNBC, TV program, February 2011