Tax and subsidies

Tax preferences and subsidies

With our planning, consulting and advocacy services we assist our clients in the optimal utilization of the complex system of tax allowances and subsidies. We have extensive experience both in obtaining asset, investment and employment type of tax allowances and subsidies, as well as in obtaining and managing research and development benefits. We have practical experience in managing the tax subsidies that provide the film and theatre sectors financing support, which experience we can also utilize in the field of sport subsidies. We can effectively combine the planning of certain tax allowances with applications for national and EU sourced funding.

Tax planning of company groups

The group-level operation of companies opens a new dimension of opportunities in tax planning and managing tax questions, while it presumes a tax-conscious company behaviour. The decisions related to a certain group of companies might include the creation of holding and financing structures, the planning of group-level tax burdens, the optimal allocation of investments, assets, intellectual properties, employees and cash flow. In addition, as special tax regulations might apply to certain company groups, the monitoring of these is the responsibility of the whole group and the individual member companies. Such special example is the complex regulation of group taxation for VAT purposes, which gives numerous tax planning opportunities. Another example, which has recently been one of the main focuses of tax authority inspections, is the establishing and the documentation of transfer prices between related companies. Our experienced professionals are keen to assist you in all these questions.

Taxation of financing, investment and real estate transactions

Tax-conscious company behaviour and planning is especially important in the financial operations of a certain company or company group. Consideration of taxation aspects is indispensable both in the shaping of the funding, financing and equity structures of an enterprise, and in the planning of the allocation of its investments, working capital,  cash flow or profits. Our professionals have unique experience in this type of tax planning and tax-based optimization of financial planning. Equally inevitable is the previous consideration and assessment of the tax effects of financial services, bank operations,  asset-based financing and leasing-contracts, investment services and certain investment or savings operations, or even of insurance contracts. In these fields our experts are ready to take part not only in the ex-post analysis of the operations and transactions, but also in their ex-ante planning.

Tax treatment of sales and procurement

The sales processes of enterprises involve numerous taxation issues and require the optimization of various tax risks. We are ready to assist in tax planning, law interpretation, management consulting or even in minute technical issues, such as the following:

  •  planning and evaluation of marketing and sales programs
  • tax planning and documentation of international carriage, transportation and logistics processes
  • determination and documentation of transfer prices of procurement and sales within company groups
  • establishment of tax optimized supply chain processes

In dealing with the above or similar issues we pay special attention to the proper application of related VAT regulations, environmental product tax and custom regulations, and the statutes and regulations that determine the documentation of transfer prices between related companies.

Taxation issues of employment

Numerous fields of employment raise complex taxation issues. Employees’ payroll calculation, the taxation optimization of their regular and bonus income may produce numerous tax risks. In the field of social security payment and personal income tax we are ready to provide general consulting, process-based or risk assessment reviews. We can also contribute to the company-level planning, optimization and administration of training, education and entertainment expenses. In the field of executive/management and employee benefits, ESOP and incentive programs and cafeteria systems we provide the following services to our clients:

  • review of existing general compensation and bonus systems
  • planning of effective compensation programs, contribution to the preparation of internal regulations,  introduction of the program, preparation of presentations and informants for the employees
  • special consultation about cafeteria systems, preparation of benefit-packages, their system-level planning and documentation
  • contribution to the introduction of cafeteria programs, preparation of internal regulations, informants for the employees
  • preparation of customised employee stock programs and other share programs from planning, through announcement and authorisation until both the preparation of internal documentations, regulations and informants, and the transaction/implementation of the program
  • detailed planning and implementation work in the field of executive stock- and share-plans

Apart from the above, with our specialized knowledge we are ready to support the planning and settlement of the tax issues of both local employees and of expatriate employees and employees with out-work contracts.

Appeal against tax authority decisions

We are able to help our clients’ authority issues starting from the preparation for tax authority reviews. We provide professional support during authority reviews, and in view of the expected tax authority statements and review notice we assist in the preparation for occurring legal redress procedures. Based on our comprehensive experience we are able to professionally contribute to the following procedures during the legal redress process:

  • comments on the review minutes issued by the authority
  • appealing against first instance decisions
  • challenging of second instance court decisions, if necessary, submitting a request for review by the Supreme Court, in which the legal representation is ensured by our lawyer partners
  • initiation of supervisory procedure against the final tax authority decision, and further appealing in case of an unfavourable outcome

 

Apart from following through and giving comprehensive professional support of specific legal disputes, we have extensive experience in challenging domestic tax statutes that violate constitutional law principles or EU derivatives at the Constitutional Court, European Commission or the European Court.