Tax

Tax

We offer a full set of tax services to our clients. Our services include the identification of tax related risks, implementation of tax strategies and solutions, support in tax compliance and clearance procedures, as well as representation in tax related disputes and disagreements with tax authorities, and in particular:

Corporate Tax compliance

We assist our clients in interpretation of corporate income tax rules in terms of particular situation for individual companies, identification of potential tax risks and areas for improvement, as well as identification of possibilities for tax savings. We provide our clients with analysis of possibilities for savings in respect of WHT, analysis of specific complex deferred tax issues and identification of possible solutions and keep them up-to-date with new tax developments affecting their business.

Corporate tax planning and structuring

We analyze and recommend the most appropriate type of business presence based on your business objectives, analyze tax implications of alternative expansion models (establishing new subsidiary or branch, entering into joint venture etc.), set up a tax efficient and flexible financing structures, analyze possibility of utilizing local Serbian tax incentives and those available within Serbian double treaty network, as well as provide full implementation support.

We carry out full legal support in conducting tax clearance procedure and provide consulting services on transactions of our clients ensuring that such tax clearance is made in compliance with the tax laws and requirements of tax authorities.

Tax litigation

We support our clients in cases of tax inspections, tax offence and penalty procedures, tax disputes before tax authorities and administrative courts. Our service includes drafting of comments to tax minutes, drafting of appeals to first instance tax authority decisions and representing the clients in front of the relevant administrative courts in procedures for challenging second instance tax authority decisions.

Transfer pricing

We review existing documentation supporting transactions with related parties to confirm completeness and identify the areas which need amendments or additional assessment of the risk of non-compliance thus ascertaining exposure to CIT, penalties and fines. We also advise clients on identification and understanding of transactions with related parties (types, volume, pricing mechanisms and contracts), review the existing group transfer pricing documentation to assess its applicability and appropriateness for use in the local company.

Tax Structuring

We provide services that include a range of solutions designed to reduce direct and indirect tax costs through the use of efficient structuring techniques and trading arrangements. We assist with group tax-planning programs and tax-efficient group reorganization, where we can help you to align tax/fiscal and operational models, attain sustainable structural tax improvements, increase shareholder value and cash flow, as well as to obtain the flexibility to accommodate future business changes.

Tax Due Diligence and M&A

We provide full legal support in reviewing the overall tax structure of planned transactions, identify key tax issues and possible deal-breakers and often suggest alternative tax approaches.

Our tax due diligence is primarily focused on corporate tax, social security and VAT issues and identification of potential tax exposures and opportunities. Our team performs the analysis of the historical decisions of tax authorities and assists in understanding industry specifics that affect the tax implications of the deal.

We analyze potential hidden costs and commitments and assist in development of negotiating positions, in particular by implementing tax due diligence findings into Sale-Purchase Agreement i.e. representations and warranties, indemnities or price adjustments mechanism.

Our team provides full support in closing of the transactions from the tax perspective by assisting in compliance / clearance procedures before the local tax authorities and managing double taxation issues thus minimizing tax-related transaction costs.

Legal opinions

We make comprehensive examination of the different types of taxes that may be imposed upon a particular business, as well as the various taxing in which it may have sufficient connection to be subject to such taxes. We analyze legal regulations regarding the type of tax applicable to your business activity, comparing them with everyday practice and expert opinions of the Serbian tax authority. By getting these tax legal opinions we give to our clients required in-depth industry knowledge and specific expertise of the tax issues inherent to their sector.