Simplifying Things . . .

We support our clients at each stage of their tax-related matters.

Our goal is to design the most effective structure to be implemented, and – together with legal counsel – to draft well-working transactional documentation. We regularly assist on both domestic and cross-border dealings. In particular, this includes:

•    Conducting of buyer's / vendor's due diligence,
•    Evaluation of implications upon asset and share deals and/or acquisition of the enterprise,
•    Full package services upon (de)mergers, cross-border changes of seat and other transactions,
•    Financial structuring,
•    Revision of cash-flows within (international) tax structures,
•    Structuring of reorganisations,
•    Tax flow modelling,
•    Designing of divestments.

We have many years of experience with all kinds of transactions. We have participated in some of the largest deals that have been conducted on the Czech market and by Czech investors abroad.

We have worked on numerous significant investment projects of foreign investors in the Czech Republic, as well as Czech undertakings abroad. Consequently, we have a broad knowledge of tax regimes in many jurisdictions.

Specifically, these assignments have included:

• Designing of tax effective international structures or its revision,
• Financial structuring focused on tax deductibility of interest costs and WHT leakage,
• Structuring of ownership structures for motor yachts and aeroplanes,
• Transfers of personal assets into family trusts and foundations,
• Designing and implementation of foreign investment funds,
• Full package structures for initial coin offerings (ICOs),
• Revision of foreign employment structures,
• Minimisation of withholding tax leakages,
• Asset protection,
• Changes of seat, incl. change of tax residency status,
• Evaluation of criteria for existence of permanent establishment.

We support family offices, high net wealth individuals and their families in dealing with all tax matters.

Our task is to handle all compliance obligations, structuring ownership structures of personally used assets and implementation of multigenerational inheritance structures. In this respect, we usually:

• Design the ownership structures of family property, incl. its protection and forms of take-over between generations, incl. inheritance,
• Design & implement Czech and foreign family trusts and foundations,
• Design international structures for ownership of foreign assets,
• Deal with all personal tax matters of family members,
• Design appropriate renumeration for key personnel of private companies.

We provide support to investment funds in relation to its establishment, operation and dissolution after the investment period.

Our assignments regulary comprises:

•  Structuring of traditional Czech and foreign investment funds,
•  Designing of non-regulated alternative investment funds,
•  Revision of operation cost structure in terms of VAT deduction,
•  Revision of VAT regime of investment management services,
•  Tax structuring of investments and divestments, incl. its financing,
•  Preparation of fund legal documentation,
•  Evaluation of eligibility for special tax regime for investment funds in the Czech Republic,
•  Designing structures of renumeration of investment managers.        

We provide representation before tax authorities as well as in court proceedings.

Since tax authorities have gained greater power, it is vital to manage a tax proceeding from its very beginning. In this respect, our work includes:

• Negotiation with the Czech and foreign tax authorities,
• Representation of clients before the tax authorities in the event of proceedings such as tax audits, appeals of first instance and representation in front of the administrative court,
• Preparation of applications for binding rulings,
• Preparation of documentation to be discussed on regular meetings of the Czech Chamber of Tax Advisors and the Czech Tax Directorate,
• Negotiations with the Czech Ministry of Finance on law changes.

On an ongoing basis, we support corporations and individuals in any necessary tax matters. We assist in the meeting of all compliance obligations, as well as interpretations of tax laws. In this respect, we offer:

• Preparation of all tax reporting, registrations etc.,
• Revision of legal documentation,
• Preparation of written memoranda and other interpretations of tax legislation,
• Preparation of documentation for official standpoints of the Czech Chamber of Tax advisors and Ministry of Finance,
• Structuring of management remuneration schemes, incl. ESOPs,
• Preparation of applications for binding rulings,
• Assistance with redomiciliation,
• Preparation of transfer pricing studies and documentations, incl. benchmarks and binding rulings,
• Preparation of documentation for research & development allowance,
• Revision of business models.