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rutland ježek also provide comprehensive tax advisory services. Building on our experience, we are able to offer clients innovative and tailor-made solutions as part of combined legal and tax assistance.
Our tax advisory practice is geared towards two main activities. The first one is based on close cooperation with the legal team and consists of closely coordinated tax assistance to all forms of legal services. The second one is in response to the ever stronger tax impact of the new ways in which holding groups cooperate globally, and focuses on transfer pricing and related tax issues. Both areas of service are informed by a philosophy of maximum focus on the client's individual situation and seek to maximize the efficiency of services rendered.
Supporting tax advice focuses on optimal tax solutions for transactions contemplated or implemented by the client. At the same time, we take care to identify opportunities for tax optimization. Our tax support also includes the subsequent implementation of the structure of the client's choice. As a part of these activities, rutland ježek offer their clients in particular the following services:
- tax planning for investments and restructurings for natural persons and legal entities, including also proposals for exit strategies from the point of view of capital gains tax
- offshore structures
- assessment of tax risks in to-be-reviewed companies and assistance aimed at minimizing the consequences of these risks
- assessment of the tax consequences of ownership restructuring within holding groups
- support in optimizing the tax strategy for doing business in the Czech and Slovak Republics or other jurisdictions
- tax support for post-acquisition restructurings, both on the level of the company and of natural persons
In connection with these services, we procure solutions for other expert issues that may arise in the course of the above-mentioned processes, drawing upon the expertise of our cooperating advisors in auditing, tax, accounting, payroll, and management consulting.
The second area of services we offer is informed by our long-term experience with transfer price issues and comprises professional support in setting transfer prices such that intra-group transactions among affiliates are based on prices which are at the same time justifiable vis-à-vis the authorities and favorable in terms of the tax burden. Our cooperation on such projects will take diverse forms depending on the needs of the client, and may for instance include:
- assessment of the current setup of intra-group transactions in terms of the tax consequences, with the goal to identify both standard tax risks and specific risks arising from faulty transfer pricing
- analysis of the business model of holding groups and identification of opportunities for tax optimization within a justifiable framework of transfer prices
- proposals for tax solutions to various business models and transactions
- reviews and comments regarding existing transfer pricing documentation
- drafting transfer pricing documentation for proposed or extant business models
- assistance in procuring binding legal opinions on the tax consequences of commercial transactions