Read also Estonian CIT in practice Unnam silent partnership agreement The argumentation present in the application was positively assess by the tax authorities. In the interpretation of February the director of the National Tax Information agre with the company no. KDIB SG He remind that the silent partnership agreement is conclud on the basis of Art. of the Act Civil Code , principles of freom of contract as an unnam contract. The doctrine indicates that a silent partnership consists, by definition, in the undisclos participation of one entity silent partner in the profit generat by an enterprise run by another entity in exchange for a contribution. The director of KIS point out that being a party to the silent partnership agreement was not mention in Art.
point of the Act as holding shares
Shares in the capital of another company or all rights obligations in a company that is not a legal person, situations that prevent the use of lumpsum taxation on the income of companies. The condition of not having shares shares in the capital of another company will not apply in this case, because the silent partnership is not a legal entity, therefore it South Korea Phone Numbers List does not have legal personality Klimkiewicz Deplano Katarzyna Lump sum on company income, the socall Estonian CIT – a way to ruce the tax liability or an additional source of risk? Analysis of tax law regulations the practice of applying Estonian CIT He emphasiz that participation in a silent partnership.
Cannot be equat with all the rights
Obligations of a partner in a partnership. The Code of Commercial Companies regulating partnerships provides for the institution of all the rights obligations of a partner in a partnership, while the Civil Code does not contain relevant regulations in this Latest Bulk SMS regard. Thus, the conclusion of a silent partnership agreement by the company does not exclude, pursuant to Art. j point of the CIT Act, the possibility of applying taxation in the form of a lump sum on the income of companies. Price for you Estonian CIT in practice Stefaniak Mariusz, Maciej Guzek Check WE RECOMMEND Estonian CIT silent partnership settlements As it turns out, not in every case the conclusion of the articles of association will result in the loss of taxation under the Estonian CIT rules.
