Direct tax consulting

Our M&A tax team provides clients with the benefits of international expertise and in-depth understanding of the local business environment. Our solutions include:

• Due Diligence reviews

We identify potential tax liabilities, evaluate the tax benefits of asset or share deals and address issues which may affect the deal price and contractual framework. We take into consideration all Bulgarian taxes and similar levies, as well as the applicable statutes of limitation. This approach results in an improved valuation and overall assurance to both current and future investors.

• Advice in structuring the transactions

We evaluate the tax impact of the transaction on both the company and its shareholders and assist in minimising a group’s tax burden and enhance cash flows and profits. We examine deductibility of transaction costs, consider the impact of the Bulgarian thin capitalisation / interest limitation restrictions and advise on available tax planning opportunities, including specific tax incentives (where relevant).

• Post deal advice and assistance

In the period after a major transaction – merger, acquisition or buyout – it is imperative that management is able to rapidly and effectively implement its business strategy. Our services during this critical period will help ensuring that tax is a controlled and value-driven function.

We help our clients analyse inter-group and related party transactions and adapt their transfer pricing policies to the local conditions and requirements. Our assistance includes:

• Development of transfer pricing policies
• Preparation of benefit test analysis substantiating the actual provision of services by related parties and the respective benefits derived
• Analysis of inter-company agreements in order to identify transfer pricing issues
• Analysis of proposed business models or group business restructurings from a transfer pricing perspective
• Assistance in complying with the Country-by-Country reporting requirements  introduced in Bulgaria in FY 2017
  
• Assistance during tax procedures performed by the tax authorities in the transfer pricing area (i.e. tax checks, audits, advance clearance procedures)
• Providing assistance to international clients regarding transfer pricing issues (e.g. Mutual Agreement Procedure)

We advise clients on planning transactions and/or business operations triggering local taxes and duties as well as support them in the completion and filing relevant compliance documentation under the applicable legislation.

We support our clients in analyzing tax incentives applicable to their business and in obtaining relief under favorable tax and customs regimes.

Our assistance includes a review of the business model, product flow, and relevant documentation, as well as providing advice on potential tax incentives and guidance on how to meet the eligibility requirements. Our experts can also assist with the collection and preparation of the necessary documentation.