Simplifying
Things . . .

We support our clients in tax related matters they face within all stages of transaction.

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

• Conducting of buyer's / vendor's due diligence,
• Evaluation of implications upon asset delas and share deals and/or acquisition of the entreprise,
• 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 modeling,
• Designing of divestments.

We have many years of experience with all kinds of transactions. During our careers, we participated on the largest deals that have been conducted on the Czech market and by the Czech investors abroad.

We worked on numerous significant investment projects of foreign investors in the Czech Republic and Czech undertakings abroad. As a result, we have a broad knowledge of many tax regimes in tens of jurisdictions.

These assignments included in particular:

• 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 airplanes,
• Transfers of personal assets into family trusts and foundations,
• Designing and implementation of foreign investment funds,
• Full package structures for initial coin offerings,
• Revision of foreign employment structures,
• Minimalisation 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 remuneration of investment managers.

We represent in front of the tax authorities or in the court proceedings.

Since tax authorities became more powerful, it is vital to manage the respective tax proceedings from its very beginning. In this relation, our work includes:

• Negotiation with the Czech and foreign tax authorities,
• Representation of clients in front of the tax authorities in case of tax proceedings, incl. 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 ongoing basis, we support corporations and individuals in any tax matters. We are assisting with meeting of all compliance obligations as well as intepretations of tax laws. In this respect, we offer:

• Preparation of all tax reporting, registrations etc.,
• Revision of legal documentation,
• Preparation of written memorandums 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.