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Structuring the acquisition or sale or restructuring

Transaction structuring

The structuring of purchase or sale transactions and their financing aimed at ensuring tax efficiency.

The structuring of transactions is aimed at ensuring tax efficiency.

Within restructuring of any capital groups, we support our Clients in mergers, demergers, in-kind contributions, disposals etc. M&A tax group support involves assistance in process planning, preparation of timeline, definition of any tax obligations and liabilities, applications for tax rulings, and ongoing tax advisory.

 

Our works include assistance in analysing possible acquisition/sale/restructuring and financing options as well as tax structuring of the purchase or sale transaction and its financing to ensure its tax efficiency. KPMG performs analysis of transaction-related tax liabilities including withholding tax on interest and dividends, thin capitalisation restrictions, companies’ substance, the impact of OECD and BEPS rules, GAAR clause and transfer-pricing obligations.

As part of our services we prepare a report (a strawman paper) that presents the main, relevant tax implications for the given transaction.

Our services include collaboration with the Investor’s legal advisors, which allows us to analyse and comment on the provisions contained in legal documents, including the share purchase agreement (SPA). Our works also include analysis of other transaction/restructuring documents. Based on the documents provided, we assist in identifying areas exposed to tax risk, and we propose amendments to provisions that might lead to unfavourable tax implications.

In respect of asset deals, the M&A tax team prepares an analysis of the status of assets for their proper qualification for VAT purposes, applications for tax rulings, price split, real estate tax analysis, VAT analysis, appropriate rates assignment as well as assistance in VAT recovery.

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