International taxation

When doing business, it is essential to assess tax obligations where there are two or more tax jurisdictions involved. Whether you are a foreign company doing business in Slovakia, a Slovak company with business activities abroad or a manager or an employee working in several countries, you will be provided with comprehensive legal assistance in the area of ​​international taxation.

In recent years, we have seen substantial toughening of international income taxation rules. The efforts of states to prevent base erosion and profit shifting affect many entrepreneurs, even those for which tax benefits are not in the center of their interest.

In order to run your business in several countries, we offercomprehensive advice based on a thorough understanding of double tax treaties, the OECD Model Tax Convention on Income and on Capital, the OECD Commentary and other OECD documents. We also closely monitor the development of the decisions of Slovak and foreign courts, as well as the increasing activity of the Court of Justice of the EU in the field of taxation. We are ready to evaluate the trends of further development, so that you can prepare for future tax impacts.

In the field of international taxation, we offer comprehensive legal advice in the following areas

  • selection of the right double tax treaty and assessment of its practical impact on your business activity;
  • evaluation of the tax treaties application according to the latest OECD documents;
  • evaluation of the multilateral instrument application for specific double taxation treaties;
  • assessment of the tax regime applicable to different types of income (including, but not limited to, royalties, dividends, interest, employee and sportsmen income, property income, and others);
  • evaluation of the existence of a permanent establishment and of the related tax risks;
  • advice on how to eliminate double taxation within legal limits;
  • evaluation of the rules for controlled foreign companies;
  • tax structuring according to your specific requirements, while respecting all tax and other legal framework.
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