Tax Advisory

Effective tax planning is built not on aggressive or purely formal structures, but on well-considered, economically substantiated solutions. Our team analyses business operating models, group structures, and the nature of specific transactions to identify tax optimisation opportunities. We offer solutions that deliver tax efficiency while maintaining full compliance with applicable regulations and reducing long-term tax exposure.

There are many situations in which an independent, legally grounded opinion on the tax treatment of a particular transaction or structure is essential. Drawing on the client's objectives and the applicable regulatory framework, we prepare tax opinions that provide clarity in decision-making and serve as a reliable foundation for all parties involved. In addition, we conduct tax risk assessments that enable potential issues to be identified early and addressed before they develop into material risks - particularly where significant transactions or structural changes are being contemplated.

We advise on tax questions that businesses and individuals encounter in the course of their everyday commercial activities and personal or business transactions. Our advisory covers the assessment of tax consequences of transactions, analysis of the applicable regulatory framework in specific situations, and the development of practical solutions. We support accountants, lawyers, company directors, and private individuals in making well-informed decisions, reducing tax risk, and ensuring compliance with current tax legislation.

We assist in designing and evaluating transaction structures to ensure that each transaction is clear, legally sound, and practically executable. During the planning phase, we analyse available structuring options and their legal, tax, and financial consequences, so that risks can be identified early and ambiguities resolved before the transaction is executed. Our goal is to create transaction structures that comply with regulatory requirements, align with the client's business objectives, and ensure a secure and efficient completion of the deal.

Transactions with foreign counterparties or business operations across multiple jurisdictions frequently give rise to additional complexity in the application of tax rules. In such situations, what matters is not only a thorough knowledge of the relevant regulatory framework, but also a practical understanding of how international agreements and established practice are applied in specific transaction contexts. We help clients structure cross-border transactions, assess the associated risks, and identify solutions that are both practically achievable and legally robust. We also advise on the application of international legislation, ensuring that it is applied in a manner consistent with its purpose and the particular circumstances of the case.

In an increasingly globalised environment, transfer pricing is one of the most significant areas of tax risk and international business practice. Our team provides a comprehensive suite of transfer pricing and group transaction structuring services:

• review and in-depth examination of existing transfer pricing policies;
• preparation of transfer pricing documentation, including documentation for low-value-adding services;
• economic analyses and benchmarking studies using comparable market data;
• transfer pricing planning;
• advisory on group transaction structuring and value chain analysis;
• preparation of intercompany agreements;
• design and implementation of intellectual property structures;
• support in advance pricing agreement (APA) and mutual agreement procedure (MAP) proceedings;
• planning and preparation of group cost contribution arrangements (CCA);

In situations involving uncertainty or disputes, well-considered, consistent, and professional communication with public authorities is of paramount importance. We support clients in their dealings with the State Revenue Service, preparing information requests, explanations, substantiated legal and tax positions, and the requisite supporting documentation. We represent clients during tax audits and examinations, providing a structured approach to the preparation of information and articulating the applied solutions. Our aim is to foster constructive dialogue with the authorities and achieve a practical, legally grounded outcome that is acceptable to the client.

When planning transactions, investments, or corporate reorganisations, timely and thorough assessment of the target business is critical. We provide tax analysis within the due diligence process, focusing on the identification of potential risks and their impact on transaction terms and execution. This enables clients to identify potential issues at an early stage, make well-informed decisions, and structure the transaction in a way that mitigates risk and secures an appropriate outcome.

Disputes with the tax authorities can be time-consuming and complex. It is important to bear in mind that the tax authority - just like the taxpayer - is bound by law. In practice, this means that the tax authority's interpretation of the law is sometimes incorrect. Our team offers a case assessment and provides assistance where there is a genuine prospect of defending the client's interests. Our services include:

• tax and transfer pricing risk assessment prior to commencing proceedings;
• analysis of tax authority decisions and challenge strategies;
• preparation of objections and appeal documents against tax authority decisions;
• preparation of appeals to the administrative courts;
• representation of client interests in negotiations with the tax authority and in litigation.