related parties

Related parties

• The taxpayer and the person in which the taxpayer has direct or indirect majority control according to the provisions of the Civil Code, 
• the taxpayer and the person who has direct or indirect majority control in the taxpayer, according to the provisions of the Civil Code, 
• the taxpayer and another person if a third person has direct or indirect majority control in both the taxpayer and such other person, according to the provisions of the Civil Code, where any close relative holding majority control in the taxpayer and the other person shall be recognized as third parties, 
• the foreign entrepreneur and its domestic place of business, and the business establishments of the foreign entrepreneur, furthermore, the domestic place of business of a foreign entrepreneur and the person who maintains the relationship defined in points 1-3 above with the foreign entrepreneur, 
• the taxpayer and its foreign branch and the taxpayer's foreign branch and the person who maintains the relationship defined in points 1-3 above with the taxpayer,
• the taxpayer and another person if decisive influence is exercised between them with regard to identical management and the business and financial policy.

Two entities may qualify as related parties for the purpose of controlled foreign company (CFC) and capital decrease (divestment/divestiture) rules, if

• the taxpayer and other persons directly or indirectly own at least 25% of share of votes  
• the taxpayer and other persons directly or indirectly own at least 25% of capital shares
• the taxpayer and other persons directly or indirectly own at least 25% of profitshare

Group restructuring

The creation of a company group structure through which the group is able to organize its processes and operations more efficiently, manage its assets safely, and ensure the conditions for future growth, at the same time optimizing its tax payment obligations and thereby improving its competitiveness.