Investment Funds and Institutional Investors

Transactional Advisory

We provide support in tax advisory at all stages, including:

• Tax Structuring of Transactions: Planning and support in creating domestic and international investment structures along with determining their tax consequences (with particular emphasis on possible forms of financing), indicating risks, and recommendations.
• M&A: Conducting due diligence on behalf of the buyer and vendor due diligence in connection with transactions involving shares (share deal), assets (asset deal), or an enterprise/organized part of an enterprise (transfer of going concern).
• Verification of Transaction Documentation: Securing transactions from a tax, financial, and legal perspective by introducing appropriate contractual provisions and warranty and indemnity clauses.
• Negotiation Support: Providing ongoing support in negotiating the provisions of transaction documentation to ensure tax, financial, and legal security while simultaneously achieving the set business objectives.
• Tax Verification of Financial Models: This involves considering the expected tax liabilities and the possibilities for settling tax assets.
• Reorganizations: Providing legal and tax support in the analysis of potential business restructuring models and the implementation of selected models.
• Tax Memoranda: Preparation of tax memoranda that are submitted to external institutions for transactional purposes (for example: banks and other financing institutions, brokers, insurers).
• Individual Interpretations: Securing selected tax implications associated with the transaction execution.
• Exit from Investment: Strategic planning of exit options from investments, considering tax, financial, and legal aspects, profit distribution, and structuring post-divestment.
• Transfer Pricing: Within these areas, we provide tax support concerning transfer pricing for settlements with related entities.

Post-Transaction Advisory

• Analysis of the tax consequences associated with possible forms of profit distribution, with particular emphasis on the settlement of withholding tax.
• Comprehensive, ongoing tax advisory.
• Tax reviews.
• Co-sourcing of tax functions.
• Determination of post-transaction settlement models.
• Support during the reorganizations and restructuring of investment structures.
• Market conformity analyses of settlements with respected entities: establishing prices in group settlements.
• Support in applying for Advance Pricing Agreements (APA) to obtain decisions from tax authorities regarding:
• The correctness of settlements with related parties.
• Transfer Pricing (TP) reporting and compliance obligations.
• Verification of TP obligations for compliance with regulations.
• Creation of comprehensive agreements.
• Tax inspections.