As a result of the successful operation of the small and medium-sized enterprises not only their financial profit grows, but new, complex corporate entities and units are created, the product and service structure is diversified, and the functions to be performed (administration, human resources, IT, central management etc. ) are expanding. In other cases, there is a demand for changing the ownership structure (new owners may join, others may exit). Consequently, the original ownership and group structure set up at the time of starting the business may not be optimal anymore to manage the increased tasks and functions.
The transformation of the group structure is a strategic decision that requires careful planning. This involves examining the tax impact of the restructuring as well.
A tax model developed in the course of preparation phase will help in decision making. After the decision on the restructuring, detailed tax planning will present an opportunity to apply the rules of favorable tax regimes (e.g. preferential transformation/transfer of assets/exchange of shares, VAT group etc.). This way, the restructuring and the operation of the newly established group could be performed tax-efficiently.
- Analysis of the main tax considerations with respect to the restructuring from the company’s point of view in order to facilitate the decision-making;
- Preparation of the tax operation model of the new group to be established as a result of the restructuring;
- Preparation of a step plan of the restructuring process;
- Assistance in the preparation and the filing of guideline requests or binding ruling request.
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