The objective of tax structuring is to create a structure which allows a reduction of future tax rates on a lasting basis as a result of financial cost allocations, and to optimize the overall tax efficiency during the life-cycle of the investment (acquisition, holding and profit repatriation, exit).
SPA defines terms of the transaction (shares, price, obligations of the parties etc). Buyer usually asks guarantees from the vendor that tax liabilities have been properly accounted and issues disclosed and that there are no hidden tax risks.
Support in implementation aims to ensure the tax efficient structure of planned acquisition which was determined in the tax structuring process.
Post acquisition support to tax function represents the last step in the M&A process. It is an excellent opportunity to set a new course of tax department which helps to maintain a tax efficient structure.
