Regular cooperation within a group of related entities is discussed in Transfer Pricing. Here we make reference to transactions that are usually one-off transactions between the parent company and a subsidiary or a shareholder and a subsidiary.
It is usually:
- a non-monetary contribution by owners
- a one-off sale of assets within a holding, including the owners
- granting loans, providing guarantees within a group of related entities (for the benefit of owners)
These transactions must be made under market/fair terms or at arm’s length.
Having an expert opinion results in:
- markedly reducing the tax risk exposure of a company and its owners
- reducing the risk of the transaction being challenged by minority owners/creditors
- having proof of the transaction having been made with due managerial care
What you can expect from us
The RSM CZ expert institute will value a transaction between related entities or review its price. We will also be happy to prepare an expert opinion explicitly required by the Business Corporations Act or other legislation. In particular:
- an expert opinion on the valuation of a non-monetary contribution under Section 143 et seq. or Section 251 et seq. of the Business Corporations Act
- an expert opinion to determine the value of the assets acquired from a founder or a shareholder in the regime of Section 255 of the Business Corporations Act (this covers stricter statutory requirements over the first two years of a company’s existence)
- an expert opinion to determine the value of various types of assets, such as an enterprise, part of an enterprise, property interests in other companies, real estate, movable property, trademarks etc., transferred between related entities
- assessing/determining interest rates on loans or guarantees/security
The RSM CZ expert institute has extensive experience with valuations for the purposes of relations within a holding company.