Our tax advisory service is focused on advising clients from different sectors, from large to small companies, in making business decisions in a manner consistent with tax regulations and optimal from an economic point of view. Tax Counseling includes a wide range of services within which, through close cooperation with clients, the adaptation of business processes to legal regulations is achieved.
- A written opinion on tax and accounting topics
- Preventive tax reviews
- Tax optimizations
- Tax due dilligence
- Transfer pricing
If you have a specific situation and are not sure how to apply the tax law correctly, we will give you a professional written opinion on how to handle the facts in your case.
A written opinion contains our understanding of the situation you are in, and with the relevant laws, regulations, official opinions of the Tax Administration, Double Taxation Treaties, OECD Guidelines, verdict of the European Court of Justice, which are relevant to the situation at hand, we conclude with you rationale and suggestions for action.
Preventive tax control
The primary objective of this service is to prepare you for tax administration oversight.
The purpose of exercising tax control by the Tax Administration is to give a certain right or impose an obligation on the entrepreneur (more common case).
The determinations of the taxpayer’s rights and obligations in tax supervision are particularly important since they can result in significant contingencies imposed by tax supervision and uncertainty in their settlement.
As an alternative to tax control, ALPHA CAPITALIS can offer you a “Tax Control Simulation” service in which ALPHA CAPITALIS employees act as if they have come to perform full tax control of the company (VAT, income tax, corporate tax and other areas within the jurisdiction of the Tax Administration).
The benefit of the client is that he / she knows at a reasonable price what to expect in the event that his / her tax control is announced and what steps should be taken to eliminate or reduce such risks.
Alternatively, if you are already in the stage of initiating a tax control process, we can assist you in drafting a Tax Record Complaint or compiling a Tax Decision Appeal, and also accompany and advise you on any other tax control procedures.
The goal of the tax optimization service is to draw the client’s attention to the business savings opportunities through the tax optimization process. The idea of this service is to analyze the tax accounting documentation and using certain tools to identify facts and events for which the company pays more taxes than it should in a tax-optimal combination that would not disturb the operating concept of the company.
Tax Due Diligence
In addition to financial due diligence, for our clients we do a due diligence of a company or business venture with an emphasis on the tax part. The years of experience we have gained working with numerous domestic and foreign clients allows us to focus on the key elements of the business that you need to familiarize yourself with before making important strategic decisions such as buying or selling equity in your own company or the company you want to take over. At the time of the decision to sell or buy or to merge or merge companies, it is extremely important to have valid information on the state of the company in question. Specifically, the idea of tax due diligence is to quantify tax risks before the transaction is completed, in order to make the transaction participants transparently aware of the risks that the entity that is the subject of the transaction carries, ie how much cash outflows there are in the event of tax oversight after the transaction is completed.
Transfer pricing broadly refers to all the terms and conditions that apply to transactions occurring between affiliates established in different countries. In a narrow sense, these are internal prices that affiliates invoice each other when exchanging services and goods.
For this reason, taxpayers who have affiliates that pay income taxes at different rates, are exempt from tax (for whatever reason), or have affiliates that pay taxes in other tax jurisdictions (at potentially lower rates), can consolidate more net income by transferring the income tax liability to a company that does not pay it or pays it at lower rates.
However, there are legal provisions on the basis of which the Tax Administration has the legal basis to ensure that every Croatian taxpayer has paid as much corporate income tax in Croatia as he would have paid if he had had exclusively relations with unrelated persons.
We draw attention to the fact that the provisions of the Corporate Income Tax Law define that business relationships between related parties will be recognized only if the taxpayer disposes of and at the request of the tax inspector submits a transfer pricing study. For this reason, it is recommended that a study be carried out before the conclusion of the price of services or goods to affiliated companies and that invoicing be carried out in accordance with the market prices determined according to the study or at the latest before requesting the Tax Administration requests to see the transfer pricing study.
In the absence of a transfer pricing study, the Tax Administration has the possibility of adjusting the tax base, charging default interest, and charging penalties. A timely transfer pricing study is the only option to minimize the risk of adjusting your tax base.
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We are glad to give you advice and active support thru all stages of business development