Applications for tax rulings
To say that tax legislation is subject to frequent changes and is complicated is an understatement. Equally risky to the incorrect application of tax regulations is deeming your planned transaction to constitute tax law circumvention.
A tool for obtaining assurance and security with regard to the application of tax regulations is an individual tax ruling. When preparing applications for tax rulings, we are guided by the best interest of our Client – which not always means obtaining a ruling confirming the position of the Client (although we make every effort to make it happen). The priority for us is to learn the tax authorities’ assessment of the facts presented in a comprehensive and exhaustive manner.
Transfer pricing documentation
Control of prices used in relations with affiliates has been mentioned in the last few years as one of the main objectives of the revenue administration. The consequences of using non-market prices can be either serious (if purely financial) or very serious (if financial and criminal fiscal at the same time). We advise our Clients on the obligation to prepare the documentation and we develop its wording.