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However the prospect is to conclude an agreement on the basis of which the company would become the socall partner in a silent partnership. The company’s doubts were whether the conclusion of such an agreement would exclude the use of Estonian CIT. with this question, the company turn to the tax authorities, submitting an application for an individual interpretation. Check in LEX Subject conditions of Estonian CIT taxation step by step procure Simple ownership structure The applicant was not sure whether he would meet the condition of a simple ownership structure under Art.

point of the Act Pursuant to

The wording of the provision, the taxpayer may not have broadly understood capital relations be a party to fiduciary relations. Importantly, for the assessment of this condition, the size of the capital commitment or the existence of mutual links South Korea Phone Numbers List is irrelevant explains Bartosz Przybysz, tax advisor at Mentzen Law Firm, author of the application for interpretation. The expert adds that the key to the decision was that the silent partnership was not regulat in detail in the Commercial Companies Code or the Civil Code, so it is difficult to conclude that we are dealing with a separate organizational unit A favorable argumentation path was determin by the assumption that a silent partnership is only an obligation.

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Relationship arising on the basis

Of the principle of freom of contract. The participation of a silent partner does not lead to the creation of any community with a register partner. The silent partner is also not responsible for the company’s obligations, emphasizes BTC Database EU Bartosz Przybysz. In his opinion, there is also no doubt that the conclusion of the said agreement will not result in the creation of a partnership or a capital company. However, it should be not that Art. j point of the CIT Act is not limit to involvement in these entities, this applies to possession of certain property rights. This circumstance could raise justifi doubts points out Bartosz Przybysz.

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