Legal · Tax · Restructuring

Tax matters and disputes

Tax law handled by lawyers: with an eye on how the tax office, and if it comes to it a court, will read the matter.

Every matter starts with a written proposal on scope and fee. Services can be combined.

Typical matters in this area

Tax audit defence

A tax audit has been announced

What this helps you avoid An additional assessment with penalties that a better-prepared file would have prevented.

What is included

  • File review
  • Representation
  • Appeal
Details

Not included in the price

  • Court fees in an administrative action
  • Expert reports

What affects the price

  • Taxes and periods audited
  • Volume of documents

Pricing

Hourly, with a cap

Discuss this matter
Transfer pricing documentation

Group transactions need documenting

What this helps you avoid Adjustments and penalties for missing or weak documentation.

What is included

  • Master and local file
  • Benchmarking
  • Annual update
Details

Not included in the price

  • Translations of foreign documents

What affects the price

  • Number of transaction types
  • Number of group companies

Pricing

Fixed once the scope is agreed

Discuss this matter
Tax opinion

A transaction or structure raises a tax question

What this helps you avoid Committing to a structure before you know its tax cost.

What is included

  • Analysis of the facts
  • Written opinion
  • Binding ruling request where useful
Details

Not included in the price

  • Authority's fee for a binding ruling

What affects the price

  • Number of taxes and countries
  • Whether a binding ruling is requested

Pricing

Fixed once the scope is agreed

Discuss this matter
Tax appeal and court action

The tax office has issued an additional assessment

What this helps you avoid An assessment that becomes final only because the appeal deadline was missed.

What is included

  • Appeal against the assessment
  • Action before the administrative court
  • Cassation complaint to the Supreme Administrative Court
Details

Not included in the price

  • Court fees
  • Expert reports

What affects the price

  • Amount assessed
  • Number of points in dispute
  • Whether the matter goes to court

Pricing

Hourly with a cap for each stage, or statutory tariff

Discuss this matter
Withheld VAT refund

The tax office is holding back our VAT refund

What this helps you avoid Months of withheld cash because the replies did not give the tax office what it needed to close the review.

What is included

  • Replies to requests and evidence for the invoices in question
  • Representation in the audit or local investigation
  • Interest on the delayed refund, where it is due
Details

Not included in the price

  • Expert reports
  • Translations of documents

What affects the price

  • Size of the refund
  • Number of suppliers and invoices questioned

Pricing

Hourly, with a cap

Discuss this matter
Tax structuring of a transaction

We are planning a holding, a share sale or moving assets within the group

What this helps you avoid A structure the tax office later treats as artificial and taxes accordingly.

What is included

  • Options compared for income tax, VAT and withholding tax
  • Review against anti-abuse rules
  • Sequence of steps and the documents for each
Details

Not included in the price

  • Fee for an advance ruling
  • Valuation by an expert, where required

What affects the price

  • Number of countries and companies
  • Number of steps in the structure

Pricing

Fixed per phase

Discuss this matter
VAT registration

We need to register for VAT in Slovakia or the Czech Republic

What this helps you avoid Penalties and VAT assessed for a period when you should have been registered and were not.

What is included

  • Whether and from when you must register
  • The application and replies to the tax office's questions
  • Registration of a foreign company, including representation before the tax office
Details

Not included in the price

  • Translations and certified copies

What affects the price

  • Domestic or foreign company
  • Type of supplies

Pricing

Fixed once the scope is agreed

Discuss this matter

Documents for your internal approval. What you can take to your board, CFO or bank before anything is signed.

  • Engagement letter: scope, fee, dates
  • Contract for legal services
  • Conflict check confirmation
  • The lawyer assigned to work with you
  • Professional liability insurance certificate

Contact

Tell us what is going on.

Or write directly

office@konfrero.com+421 948 209 013
BratislavaPlynárenská 1, 821 09 Bratislava
Slovakia
PraguePod dráhou 1637/2, 170 00 Praha 7
Czech Republic
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