Company restructuring

 

Reorganization of the business

For entities that have made or want to make:
  • merger, division or acquisition of entities
  • transfers of assets (including intangible assets) of key importance to the business
  • transfer of the entire enterprise or its organized part
  • transfer of rights resulting from significant contracts
  • a significant change in the functional profile of a given entity - taking over new, significant functions or ceasing to perform them
contact
  • to transfer significant assets, essential functions, risks
  • for a business case
  • on the marketability of the transfer
  • for a contractual change in the terms of cooperation, if it significantly changes the existing distribution of risks and benefits
Contact
  • tax opinion on the planned business reorganization
  • assessment of tax risks
  • assessment in the aspect of the tax law circumvention clause
  • tax audit
  • assessment of the obligation to notify the MDR tax scheme
  • transfer pricing documentation
Contact
 

Characteristics of the reorganization

For entities that have made or want to make:
  • reorganization involving the transfer between related parties of functions, assets or risk categories
  • a reorganization involving a material change in the business or financial relationship
contact
  • for reorganization involving a significant change in commercial or financial relations, including termination of existing contracts or change of their material terms
  • for a reorganization involving a transfer between related parties of a function, asset or risk category, if as a result of this transfer, the expected three-year average EBIT in the three-year period after the transfer would have changed by at least 20% of the expected average annual EBIT in the same period had the transfer not taken place.
Contact
  • tax opinion on the planned business reorganization
  • assessment of tax risks
  • customer case analysis in terms of business case
  • analysis of the client's case in terms of the transfer marketability
  • assessment of the obligation to notify the MDR tax scheme
  • transfer pricing documentation
Contact
Contact