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Restructurings

Tax rationalisation of supply chain management

The actions taken by capital groups, both Polish and multinational, in the area of supply chain rationalization include among others: integration of business operations / centralisation of selected business and management functions in selected, specialized entities: e.g. in the area of:

  • manufacturing, sales agency services, etc.);,
  • R&D,
  • creation of shared service centres (SSC).

In Poland...

In Poland a consistent expansion of business operations of Polish native entities and capital groups is also clearly seen. This expansion results in adapting the currently applied approach and tools to new scale and scope of business activity. It also includes valuation and optimisation of various business functions and areas of effectiveness, such as:

  • production,
  • distribution,
  • R&D,
  • intangible property (trademarks, production technology, etc.);
  • cross-border business expansion (new markets entry, relocation of production, etc.).

Enodo Advisors services in the area of tax rationalisation of supply chain management and restructuring processes create possibility to combine „pure" business goals together with capital group's effective tax rate optimisation

Who and when should consider tax rationalisation of supply chain management?

Enodo Advisors, using extensive experience gained during long years of practicing both in Poland and abroad and thanks to co-operation with our foreign business partners, offer professional support in tax rationalisation of business models and restructurings management. They are particularly useful if you plan:

  • business expansion or relocation of selected functions (e.g. new markets entry, relocation of production) to new countries;
  • integration of business operations or centralisation of selected business and management functions;
  • restructuring or rationalization of existing business model in order to improve its effectiveness / maximize the synergy effects (including e.g. reduction of costs connected with execution of selected business processes);
  • integration of operational activities as a result of mergers and acquisitions;
  • restructurings involving intellectual property;
  • creation of shared service centres.

We also believe that regardless of the above business situations which create possibilities for effective tax rate optimisation, it should also be taken into account that business expansion / restructuring covering foreign markets and tax jurisdictions results in a necessity to analyse the planned business actions from the perspective of local regulations and tax authorities' practice in this respect. In the course of our work we take into account local specific, practice and regulations in Poland as well as in major countries in Europe and Asia.

Our services

Enodo Advisors services in the area of tax effective aspects of supply chain management and restructurings cover multi-disciplinary specialization / approach. They include among others:

Feasibility study Support in analysis and valuation of planned restructuring's tax effectiveness and possibility of implementation. This includes, in particular, in direct co-operation with and based on detailed discussions with our clients, a valuation of the real possibility of re-allocation of significant / selected business functions and risk from the perspective of potential tax consequences.
Transfer pricing Design and implementation of solutions which fulfil business goals and objectives.
Transfer of undisclosed intangibles and/or profit potential Analysis of consequences of planned / executed restructuring on risk of taxation due to transfer of profit potential or other elements of intangible nature having an inbuilt value for business from a perspective of the chapter IX of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations as well as local regulations and practice.
Post–conversion transfer pricing issues Transfer pricing analyses of the following intercompany post-conversion transactional flows:
  • existing but subject to remodelling – created as a consequence of e.g. converting fully fledge producer to contract manufacturer;
  • new – created due to restructuring of existing business model (e.g. commissionaire compensation, IT services, etc.);
  • regarding charges for IP (e.g. know-how, trademarks, etc.).
International taxation International taxation services, including among others:
  • creation and taxation of PE for tax purposes (including allocation of profits to PE);
  • local regulations and tax optimisation possibilities.
Indirect taxes Indirect taxes, including:
  • verification of a planned model implementation possibilities and effectiveness from the perspective of e.g. excise tax;
  • VAT aspects of planned restructuring and post-conversion flows.
Other issues – financing, activity costs, administrative burdens Analysis, recommendations and implementation of tax effective ways of financing the investments.
Analysis of administrative issues, including:
  • costs of setting-up companies in selected countries / tax jurisdictions;
  • obligatory costs of managing new entities (including administration costs).