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Tax

Our team of tax lawyers provides comprehensive advice on the tax aspects of corporate, commercial and financial transactions. We offer our clients both support in tax issues related to day-to-day operations and advice in audit and tax proceedings, as well as a wide range of tax planning advice aimed at reducing the tax burden within the limits of current law. We take care of the tax security of our clients, but also support them in decision-making processes related to the operation of their businesses.

 

TAX CONSULTING

  • Preparation of requests for individual interpretations of tax laws;
  • Assessing the tax consequences of ongoing restructuring projects, including, in particular, divisions and mergers of business entities, issuing recommendations from the perspective of the tax consequences of such events;
  • Reviewing commercial contracts and agreements from a tax perspective, recommending optimal tax solutions;
  • Advising on tax optimization mechanisms for executives and key employees;
  • Advising on income tax, real estate tax, inheritance and gift tax, VAT and others;
  • Conducting comprehensive tax analyses of business transactions performed and planned;
  • Issuing tax opinions and providing recommendations.

 

TRANSFER PRICING

  • Preparation of transfer pricing documentation in accordance with the requirements of income tax laws,
  • assessment of the possessed tax documentation of transactions with related parties in terms of their reliability and completeness and possible risks;
  • ongoing advice on tax proceedings concerning transfer pricing issues.

 

TAX PROCEEDINGS AND AUDITS

  • Consulting in the period preceding audits;
  • Counseling during tax audits and proceedings;
  • advising on verification activities;
  • conducting inspection and tax proceedings, in particular, preparing objections and motions to tax inspection protocols;
  • Preparation of appeals and complaints in the course of tax proceedings;
  • Preparation of motions for annulment of decisions and motions for resumption of completed proceedings, as well as motions to amend or revoke decisions;
  • Advising during security and enforcement proceedings in tax matters;
  • Preparation of complaints to administrative courts and cassation complaints against judgments of provincial administrative courts in tax matters and representation during proceedings initiated by the filing of these complaints;
  • Preparation of motions in the course of court-administrative proceedings and complaints against the decisions of provincial administrative courts in accidental matters;
  • Preparation of complaints for the resumption of judicial-administrative proceedings and complaints for a declaration of the illegality of a final decision of an administrative court;
  • Counseling and representation in criminal and fiscal proceedings;
  • Preparation of opinions, analyses and reports related to tax disputes.

 

TAX PLANNING

  • Analysis of the tax consequences of the Client's intended transactions, including in particular capital transactions, as well as assessment of the tax risks arising from them and development of solutions to minimize these risks;
  • monitoring and responding to planned tax changes in the country and proposing optimization solutions adequate to the changing legal situation on an ongoing basis;
  • Developing tax analyses focused on defining possible optimization areas;
  • Preparation of reports presenting optimization strategies;
  • Evaluating the taxpayer's planned activities with tax consequences in terms of the risk of possible fiscal criminal liability.

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