A natural person develops real estate projects and carries out each of the projects through a separate company (SPV). There are over 10 companies with such projects and respective SPVs.
The client applied for assistance during the STI control actions when the STI raised questions: why do the same employees work in the companies for only a few hours; why their hourly wage is high but the total monthly wage in a particular firm is relatively low; why some companies don’t have phones, computers, cars, etc .; also raised questions about mutual loans, and so on. Not only did we help the client to defend against the STI, but we are proud that after analyzing the existing group of companies, employee functions, etc., we proposed and implemented a group structure in which the STI will no longer raise the above issues, and it will be possible to consolidate corporate tax losses (it will be possible to transfer the tax loss of one company to another company and the company that took over the loss will pay lower income tax or will not pay it at all). Thus, the proposed structure of the group of companies will allow tax losses to be “used” in the same year in which they occurred, and there will be no need to wait for the company that has suffered tax losses to earn the taxable profit.