Other Merger and Acquisition Services

After the transaction is closed, we would be pleased to provide you with the following services:

• Minimization of tax risks identified during the tax due diligence (e.g. preparation of transfer pricing documentation)
• Implementation of tax opportunities identified during the tax due diligence (e.g. application of tax reliefs not applied previously)
• Managing the tax risks arising when the acquisition structuring is implemented (e.g. comply with the requirements for the substance in the acquiring entity)
• Post-transaction tax structuring (e.g. carve-out of non-core business, de-merger of business from assets, elimination of unnecessary intermediary companies, etc.)
• Preparation of requests for non-binding or binding rulings to the Tax Authorities
• Preparation of advance pricing agreements with the Tax Authorities regarding the pricing of new transactions between related parties after the acquisition
• Assistance with tax disputes with the Tax Authorities

In order to maximize the benefits of a transaction, it is important to remember other aspects as well. We can help you in the following areas:

• Tax structuring services, the aim of which would be to ensure tax efficient acquisition of the Target, financing, operation of the Target after the acquisition, extraction of funds and exit from the structure
• Services related to tax efficient issuing of shares to employees via share option or via alternative way
• Tax consultations related to intellectual property (IP) acquired
• Review of Sale-purchase agreement from tax perspective
• Review of inter-company loan agreement, if any, from tax perspective
• Review of management fee or other agreements between related companies
• Transfer pricing services related to new transactions between related parties
• Review of calculation of goodwill, if any, for tax purposes which could be amortised over 15 years for tax purposes