Our tax practice professionals, partner Marti Hääl and senior associate Egon Talur, participated as speakers at a tax seminar organised in co-operation with the Estonian Chamber of Commerce and Industry. The topic of the seminar concentrated on the economic interpretation principle and conduct of tax audits. The audience included representatives of small and mid size retail, construction, transport, and production companies, as well as business and tax consultants.
The pre-lunch presentation focused on the actual topics of the economic interpretation principle, introducing recent court practice in the area. Additionally, our specialists presented an overview of legal problems associated with transactions involving higher risks and examined problems concerning taxation of fees, options, and dividends paid under service agreements.
The second half of the day focused on tax audits, starting with introduction of audit steps and then listing the rights and obligations of the tax controller and audit subject. Illustrative practical case studies helped the audience better understand the problems associated with tax audits.
Partner Marti Hääl specializes in devising and structuring tax-efficient business, investment, and financing models. He also has significant experience in dispute resolution, especially in tax-related litigation. The expertise of senior associate Egon Talur covers most aspects of corporate income tax, as well as value added tax and employment-related taxes. In addition, Egon advises clients on business restructuring and represents clients in tax disputes.
A recent illustrative case involving Marti and Egon concerned representing nine of the claimants in a precedent tax dispute that challenged the legality of a tax claim directed at former Sylvester shareholders (currently Stora Enso Timber). The proceedings primarily concerned implementation of conditions and limitations of the “substance over form” principle. In practice, this meant that the legal issue was whether the outcome, and hence the ensuing income tax obligation of the companies holding AS Sylvester shares and conducting a sale transaction with Stora Enso, applied to private shareholders of holding companies.
The dispute received continuous media coverage and as a result of the decision the Estonian Tax and Customs Board returned tax paid by all claimants, in addition to interest and legal costs, amounting in all to EUR 37 million.
This entry was posted in Taxation, Dispute resolution. Bookmark the
permalink. Both comments and trackbacks are currently closed.
Our professionals speakers at tax seminar
Our tax practice professionals, partner Marti Hääl and senior associate Egon Talur, participated as speakers at a tax seminar organised in co-operation with the Estonian Chamber of Commerce and Industry. The topic of the seminar concentrated on the economic interpretation principle and conduct of tax audits. The audience included representatives of small and mid size retail, construction, transport, and production companies, as well as business and tax consultants.
The pre-lunch presentation focused on the actual topics of the economic interpretation principle, introducing recent court practice in the area. Additionally, our specialists presented an overview of legal problems associated with transactions involving higher risks and examined problems concerning taxation of fees, options, and dividends paid under service agreements.
The second half of the day focused on tax audits, starting with introduction of audit steps and then listing the rights and obligations of the tax controller and audit subject. Illustrative practical case studies helped the audience better understand the problems associated with tax audits.
Partner Marti Hääl specializes in devising and structuring tax-efficient business, investment, and financing models. He also has significant experience in dispute resolution, especially in tax-related litigation. The expertise of senior associate Egon Talur covers most aspects of corporate income tax, as well as value added tax and employment-related taxes. In addition, Egon advises clients on business restructuring and represents clients in tax disputes.
A recent illustrative case involving Marti and Egon concerned representing nine of the claimants in a precedent tax dispute that challenged the legality of a tax claim directed at former Sylvester shareholders (currently Stora Enso Timber). The proceedings primarily concerned implementation of conditions and limitations of the “substance over form” principle. In practice, this meant that the legal issue was whether the outcome, and hence the ensuing income tax obligation of the companies holding AS Sylvester shares and conducting a sale transaction with Stora Enso, applied to private shareholders of holding companies.
The dispute received continuous media coverage and as a result of the decision the Estonian Tax and Customs Board returned tax paid by all claimants, in addition to interest and legal costs, amounting in all to EUR 37 million.