In addition, Highgate Law & Tax is also celebrating its win in the “Capital Markets” category, proving itself to be a comprehensive law firm with an extensive portfolio of expertise and the ability to successfully navigate diverse legal challenges.

The awards gala evening, which was organized by the media and educational group EPRAVO Group and the weekly TREND, was held at the Double Tree by Hilton hotel in Bratislava. For Highgate Law & Tax it was not only an opportunity to celebrate its success, but also to thank its clients and partners for their trust and support, without which this milestone would not have been possible.

This double triumph confirms Highgate Law & Tax’s excellent reputation for legal and tax services and reinforces its position as a leading player in the legal services market in Slovakia.

Článok Highgate Law & Tax and its double triumph in the prestigious Law Firm of the Year competition je zobrazený ako prvý na Highgate.

So let us break down what was actually adopted:

In addition to income exempt from tax under Section 9, income provided as a benefit in kind acquired by an employee in the form of employee shares valued at their nominal value or a business share in a limited liability company valued at the value of the contribution determined in accordance with Section 25a attributable to the employee in connection with the performance of a dependent activity carried out for the employer whose shares or business share is so acquired shall also be exempt from tax, if:

1. that employer has not paid profit shares (dividend) out of the profits of the company from the date of registration under section 49a until the tax period preceding the tax period in which it first paid them;
2. those employee shares have not been and are not admitted to trading on a regulated market or on a similar foreign regulated market,39b) until the end of the tax year in which the consideration was acquired by the employee

In the conditions of the Slovak business world it can be simplified as follows: the acquisition of shares from the employer for whom the ESOPist works is exempt from tax, if the employer did not pay dividends in the period from its establishment until the end of the year preceding the year in which it first paid them. The same applies to self-employed persons (“self-employed persons“).

Unfortunately, there is a relatively clear split between the ambition of the ESOP amendment and the ability of its language to bring about a general consensus on its content. While it is true that a legal text (i.e. an ESOP amendment) must enjoy a certain degree of linguistic openness, given its adoption in advance for an indeterminate number of cases, the ESOP amendment displays the basal signs of semantic and, to some extent, linguistic chaos.

Interpretation 1: If I were to settle for its mechanical interpretation, any such ESOP is exempt from tax. Indeed, every single employer did not pay dividends between the time of its inception and the time it first paid them. Such an interpretation, however, is plainly inconsistent with the authentic interpretation. The legislature did not mean to say this(see the amendment in the NRSR). Nor does the Treasury Department interpret it that way in this information (“Available Interpretation“).

Interpretation 2: It appears that both the Financial Administration and the Ministry of Finance of the Slovak Republic interpret the ESOP amendment in a relatively non-standard way, not only in terms of the possible consequences that will arise in practice, but also in terms of creating a new precedent. Namely, if an ESOPist’s interest in a company is acquired in January 2024 and a profit (of any kind) is paid out in December 2024, the employer (or self-employed person) must “tax” the January acquisition of the interest after 11-12 months. Thus, the non-cash income may be non-taxable income for a period of time and at some point in the future it will turn into taxable income. Interesting design precedent.

However, such a view has a statutory basis in grammatical interpretation, which ties the phrase “up to…” to the exemption of income from the shares received and not to the period of non-payment of dividends. A peculiar choice of syntax for such an intentional interpretation. At the same time, however, such an interpretation also has ill-conceived application consequences:

• What if the employer decides, within the meaning of Art. 3, lit. (d) of the Income Tax Act not to increase the non-cash consideration (not to use the so-called “bruting”)? In the context of certain situations under Art. 3, lit. (a) of the ITA, will the employee’s income be taxed retroactively? And what about social security and health insurance contributions?
• What impact will this have on the application of sanctions? Suppose the beneficiary of the ESOP shares is a sole trader who ceases trading in February 2024 and therefore does not include this income in taxable income. How will he include that income in the tax base so that he is not penalized?
• What impact will this have on health and social insurance premiums and related penalties?
• How will the ESOPist find out about the dividend payment subsequently if he has already sold his share in the company in the meantime?

Interpretation 3: If we accept the possibility of applying Interpretation 2, we must also accept an interpretation that says that the acquisition of a share at a price below the market price is exempt from tax, but only until the company has paid the first dividends (i.e. there is no restriction to just that one calendar year). Thus, if the company pays dividends in 2050, the ESOPist/company would have to tax the non-cash income additionally. While this sounds absurd, what prevents the state from not applying such an interpretation? Where does the ESOP amendment limit this retroactive taxation to only situations that occur in the same calendar year? Relying on a reasonable (possibly axiological) interpretation of legal norms may not be entirely reasonable in Slovak circumstances. We have seen this in the case of Andrej Kiska and his tax case. By the way, if you are interested in this topic, I gave a quick tax-law excursus on it a while ago here(Did Andrej Kiska really commit a crime as a managing director of KTAG?).

Interpretation 4: What is intended to be exempt under the ESOP amendment is “employee action.” This implies that the exemption applies only to situations where the ESOPist receives such a share for free. In fact, the ESOP amendment does not speak of exempting in-kind consideration acquired on account of the difference between the fair value of the share and its acquisition value paid by the employee. Is it sufficient to use the a maiori ad minus (greater to lesser) argument to exempt the value of the non-cash income?

Interpretation 5: The ESOP amendment does not give a firm answer even on the amount of income to be exempted from tax. The available interpretations, though, try to interpret the exemption to exempt the entire income (i.e., the fair value of the shares) and for the purpose of valuing the shares so acquired with the ESOPist, the face value of the shares is to be used. And such an interpretation is also e-ratione legis.

But the problem is that (i) such an interpretation creates a manifestly inadequate structural incoherence in the ITA and (ii) the reference in the ESOP amendment to section 25a and only for SRO interests does not quite make sense. After all, a non-entrepreneurial natural person values the acquired financial assets according to sec. 5 and not under section 25a of the ITA. Such an interpretation of the e-ratione legis thus constitutes a “pandora’s box” to the “illegibility” of the ITA. Indeed, if we were to ascribe correctness to the Available Interpretation, it would mean that for any sale of financial assets, we would have to read every single provision of the ITA and look for special adjustments to the valuation of financial assets in them. And this is in view of the wording of Art. 5, lit. a) and § 25a of the ITA is systematic nonsense. Moreover, this interpretation also contradicts the theory of taxation, which I wrote about briefly in a previous newsletter).

Thus, if the sentence structure of the ESOP amendment is viewed through the prism of the systematic method of interpretation and the theory of taxation, only the face value of the shares should be exempt from tax, not their fair value (“in-kind consideration acquired by an employee in the form of employee shares valued at their nominal value” – valued is linked to the shares and determines the amount of the exempt non-cash consideration). And in other similar situations, the difference between the fair value and the value so appraised must, again in the view of the Internal Revenue Service, be taxed and thus “taxable” as noncash income.

Be that as it may, it appears (with some degree of exaggeration) that, if the ESOP amendment had had the following operative language, “The exemption is the acquisition of shares from the employer if such exemption is equitable,” it would probably have been the same in terms of the quality of the legal standard. Given the more current lament over Slovakia’s unpredictable status as a state governed by the rule of law, this is not an ideal legislative environment.

In addition to the interpretative problems, the ESOP amendment has several other shortcomings:

• The ESOP amendment did not pay any attention to SRO contractors, who are in practice a very clear alternative to the contractors of the self-employed.
• The ESOP amendment does not allow for the acquisition of shares in, for example, a cooperative, whereas we know that it is the cooperative in more robust structures that replaces the rigidity of other legal forms;
• The ESOP amendment has limited application to absolutely standard ESOP structures where the shares are not earned directly in the executive company for which the employee/employee performs the activity, but in a specially designated company;
• The ESOP amendment may not even capture situations where the ESOPist acquires an interest in the company from a shareholder;
• The ESOP amendment pays no attention to real shares, the quality of which is legally limited (bad leaver clauses, transferability, …);
• The ESOP amendment taxes the sale of shares in an SRO but, for reasons between heaven and earth, does not tax the sale of shares.

These structures are absolutely standard and are based in part on the needs of corporate law (e.g. SROs cannot flexibly own their shares or the elimination of a high number of shareholders or a high value of the minimum contribution is necessary), the preferences of contractors as well as the requirements of investors. These needs are relatively common knowledge, so it is not clear to me why they are not reflected in the ESOP amendment.

The ESOP amendment once again fully exposed the quality and (in)competence of the standard-setting process in Slovakia. As with the crypto amendment, which for example wanted to introduce non-taxation of crypto asset exchanges (I have discussed this more in this video podcast or written in more detail here), the good intention of the ESOP amendment was not translated into appropriate language. And this significantly undermines not only the rule of law, but also the efficiency of doing business in Slovakia.

The interpretation of the ESOP amendment is therefore ambiguous and its application unpredictable. We are thus still forced to look for alternative structures and solutions for our clients than ESOP intra legem not to tax. And worse, in practice, the alternative is even situations where companies give no imperative weight to the taxation of ESOPs. In either case, it is the business environment that suffers in the long run. Namely, through unnecessarily higher costs to advisors (us) and/or the existence of an unfair, arbitrary and non-transparent environment.

If you have any questions, feel free to contact me. For more of this information, subscribe to our newsletter.

If you are interested in this topic, please do not hesitate to contact us.

Článok ESOP amendment: 5 different interpretations and we are only at the beginning je zobrazený ako prvý na Highgate.

The Highgate Group is very much involved in the subject of ESOPs. Peter Varga’ s well-known LinkedIn status (found here) has sparked further discussions and possibly even legislation effective from 2024. While the latter does not reflect all of the technical problems of the amendment in question, it at least addresses the fundamental schism between the ambition of the ESOP amendment and the ability of its language to produce a general consensus on its content.

Conferences on ESOPs

The Highgate Group has already organized three ESOP conferences. The first back in 2019, when the topic gradually filled the social space. In addition to lectures by Petr Varga and Tomáš Demo, it was actively attended by stalwarts of the Slovak venture capital world, namely Juraj Vaculík, Jaroslav Ľupták and Viktor Mikulášek.

In 2022, we organized a huge conference for IT and digital companies, where one of the topics was ESOP and a lecture by Petr Varga and Tomáš Dema on this topic.

However, given the dramatically evolving practice in this direction, the topic of ESOPs required a more comprehensive presentation, so we decided to organize a separate conference on this topic alone in 2023. The sold-out HubHub (approx. 100 people) was a clear proof that this topic is the topic not only of startups, but of a critical part of Slovak companies.

If you are interested in this topic, please do not hesitate to contact us.

Článok Peter Varga on ESOP Taxation at the Flagship Event for SLOVCA 2023 je zobrazený ako prvý na Highgate.

In three entries, we focused on best practices in Slovak companies, starting with the process of setting up a functioning ESOP program with creative suggestions for types of employee compensation and the associated minimization of tax and levy implications. We also covered approaches to properly valuing a company when issuing an ESOP, seamlessly moving on to the topic of current trends associated with issuing employee stock to the setup (different approaches) and managerial handling of Good Leaver/Bad Leaver situations.

For those who missed the conference, this article provides a small taste of what we covered at the ESOP conference. If you are interested in the topic in more depth, there is a video recording of the conference, which you can find here.

In particular, we present how important it is to set up the whole structure correctly at the very beginning of the ESOP program, taking into account the potential growth of the company, the entry of an investor or even legislative innovations, which can make the existing ESOP program more effective if set up correctly.

What to consider in an ESOP?

ESOPs are a complex topic that is not enough to look at only through a legal and tax lens. In the first step, of course, it is important to work with the ESOPist’s vision and knowledge of the company that intends to set up an ESOP program. Subsequently, other issues such as:

• Economic setup – psychology and management, Good Leaver / Bad Leaver, vesting / cliff period, option / stock / shadow stock;
• Tax setup – company valuation, taxation moments, strike price;
• Legal set-up – administration, flexibility and protection of founders/company, voting and economic rights.

Our task is therefore for the client “under one roof” to take into account all relevant facts and provide the most ideal economic, legal and tax-tax setup of the option program, including service such as:

• drafting the so-called. ESOP contracts;
• drafting the so-called. “drawer contracts”;
• Tax-tax assessment and design of a specific ESOP structure;
• suggestions to minimise the risks of a possible tax audit;
• the actual execution of corporate changes;
• setting up an ESOP structure using a foreign company; or
• Prevention as well as eventual resolution of Bad Leaver situations.

ESOP Basic Conditions

The ESOP concept brings with it many concepts, and it is necessary for the client to think about them before we start setting up a specific strategy for him or her. It is mainly a decision on what conditions will be set in the ESOP. It mainly concerns:

• ESOP pool – A percentage of the total number of shares of a company’s outstanding stock that is offered to employees as a recruitment and/or retention tool.
• Strike price – also known as strike price. The price (determined at the time of grant) at which an employee can purchase shares.
• FMV – fair market value – the price that would be agreed between a potential buyer and a potential seller, neither of whom is under any obligation to act and both of whom have reasonable knowledge of the relevant facts. Three methods are commonly used to determine FMV, namely Discounted Cash Flow, Public Market Comparables, Precedent Transactions.
• Vesting period – the period during which shares “mature”. It is up to the company to choose the period of time – for example, 4 years is standard.
• Cliff period – holding participation in an ESOP, for example, in the case of a new employee. Thus, a company may determine that the vesting period will only begin after a certain period, e.g. by a year.
• Good leaver/ bad leaver – a bad leaver clause allows the company to recover vested options of an employee who leaves under pre-determined conditions. In a good leaver, the action is essentially “maturing”.

What can cause a poorly set ESOP?

An ESOP acts as a powerful motivational and rewarding tool to attract and retain employees or reduce turnover in the company. At the same time, it motivates employees to perform better at work, which is also linked to the growth of the company. However, this is only true if the ESOP is set up correctly and efficiently. In practice, we also encounter the opposite situations where we have to deal with “dead equity” in the company, namely a “non-working ESOPist” who has already been assigned a real, tangible stake in the company.

A poorly set up ESOP can also have a demotivating effect on employees, which is the opposite of the purpose of such a program. For example, after the vesting period, an employee may lose the motivation to perform his or her job as effectively as during this period of share maturation. Therefore, it is necessary to set up the ESOP in such a way that the employees have an incentive to work or stay in the company even after the “vesting period” has expired.

One of the reasons for employee demotivation can be the poor setting of Good Leaver / Bad Leaver conditions. In practice, we often deal with a variety of “bad leaver” situations, most of which require a sophisticated and complex approach. Therefore, it is most ideal for companies to set these conditions upfront as a precaution in clear and practically enforceable language and manner. Of course, setting a fair playing field also applies to the “good leaver” situation.

When setting up an ESOP, it is more than desirable to comprehensively anticipate all potentially problematic situations and one of them is the possible dispute about the value of the share and therefore how to determine the “fair market value” (FMV), what methods to use to value a company or, for example, a Start-up with a unique product and difficult predictability of its development in the next stages, and who to contact to develop the FMV for your business model.

Types of employee “shares”

The company has a choice as to what kind of “shares” it offers to its employees. In the conditions of the Slovak Republic it is in particular:

• Share options;
• Shares and business holdings;
• Shadow business holdings/shares.

Already at this step, when choosing the type of shares, it is necessary to consider the economic and tax-tax implications. The choice of the type of shares is undoubtedly linked to the choice of the legal form of the ESOPist, where our legislation gives us four options to choose from, the choice of which depends on the specific realities of the intended structure, namely:

• Limited liability company (s. r. o.);
• Joint stock company (a. s.);
• Simple stock corporation (j. s. a.);
• Cooperative; or
• Alternative forms.

Each legal form has its specifics, or its advantages and disadvantages. Already at the conference we outlined the essential advantages of the less used legal form of the cooperative, as well as the use-cases of the correct set-up in practice. It is important to note, however, that there is no such thing as the “most correct” choice of legal form, but in any case it is very important to make a comprehensive assessment of which legal form is the most “ideal” choice for a given case.

In practice, it is relatively common to encounter the creation of an ESOP structure abroad. There are a number of legitimate reasons for this:

Standard ESOP milestones

ESOPs entail certain “milestones” which also need to clearly set the conditions under which they occur. We mean the following:

• Option grant;
• Exercise of the option;
• Acquisition Action;
• Sale of shares.

In the case of employee shares, a fundamental problem arises in practice from our point of view, namely the question of the timing of taxation. The Income Tax Act provides for the accrual of non-cash income – taxation – at the time of acquisition of employee shares by the employee. In the case of options, there are views that the moment of taxation occurs even a little earlier. However, such a procedure contradicts the principle of taxation, where taxation on the acquisition of employee shares is to occur at a point in time when neither the employer nor the employee has cash income on which tax and levies can be paid.

For our clients, we therefore try to find legal ways to set up the ESOP structure so as to divert the moment of taxation to the moment of actually received cash income, or to reduce the rate of taxes and levies, or to minimize the risks of a possible tax audit.

As we said in several case studies at the conference, each client needs to be considered on an ad hoc basis, and there is no sort of one-size-fits-all template that just rolls over to the firm without knowing the client’s requirements. In any case, we will be happy to create and run a tailor-made solution for your business with an optimal mix of legal and tax-efficient structure.

Taxation of employee/contractor ESOPs

The recently adopted amendment to the Income Tax Act has at least triggered a positive response within the startup environment. Under the rules in effect prior to this amendment, a critical portion of shares awarded to an employee or contractor had to be taxed as non-cash income. In practice, therefore, various arguments and structures have been devised to eliminate this risk. The amendment was intended to shift this taxation to the moment of realisation of income in the form of an “EXIT” share.

However, despite the certainly noble motive, the amendment does not fully address this need and it appears that it may be unused in practice without fiscal risks. It is therefore possible that the new legislation will still be subject to some changes.

Airdrops for employees/contractors and other forms of remuneration

As the ecosystem around crypto assets develops, we are increasingly seeing the distribution of various crypto assets to team members. This was also addressed at the conference.

If you are interested in this topic and would like to know more about it, a video recording of the conference is available right here below the article.

If you are interested in this topic, please do not hesitate to contact us.

Článok Employee Stock Ownership Conference (ESOPe) je zobrazený ako prvý na Highgate.

We are thus relatively intimately familiar with the related realities of this segment. Whether it is the topic of tax optimization, “employing sole traders”, investor entry, setting up a holding company, automated accounting, ESOPs, the legal, practical and tax pitfalls of scaling a business abroad, or operating with cryptos, these are all topics that we encounter in practice.

For this reason, we perceived that this conference can help many entrepreneurs to navigate through the complex tangle of more complex Slovak and foreign tax and legal issues. It was also intended to help to better understand the perspective of an investor or potential buyer in a company exit.

Sale of the company or entry of an investor :

• What are the basic situations and types of investor entry into companies?
• What are the key motivations and areas of interest for the investor and the company owner?
• What should an IT firm focus on to maximize the benefits of the investment for the firm and the business owner?
• Structured transactions and relevant tax implications from an income tax perspective (e.g. tax burden through a Slovak vs. a foreign holding company);
• Transaction Experience;

Relevant financial ratios when a company is sold or an investor enters :

• What is of interest to the investor or the buyer in accounting?
• Risks associated with incorrect accounting;
• Capitalization of the company;
• Transaction Experience;

Foreign IT contractors and work “from Bali” :

• Withholding taxes on payments to foreign contractors;
• Working from “Bali” – tax and levy implications;
• Setting up contract documentation;

ESOP – Best practice :

• What forms of shares and options can Slovak companies offer to their employees?
• Legal and practical context;
• Tax and levy context;
• Cross-border structure and practical experience;

Functioning in the crypt :

• Receiving retribution and paying contractors in the crypt;
• Types of crypto projects (token issuance, management, consulting, community token,…) and regulatory and tax aspects;
• Accounting and tax pitfalls in Slovakia and best practice when leaving Slovakia;
• Experience;

Scaling the IT business abroad :

• Do I need to have a company abroad in different business situations?
• Establishment of a permanent establishment, VAT regimes, withholding taxes;
• A company in an offshore jurisdiction from a legal, tax and practical perspective;
• Holding abroad – advantages and disadvantages;
• Investor requirements for foreign structure;
• Protection of the owner’s private property in the context of the political situation in Slovakia;
• Transfer pricing;

Software contracts :

• Framework or one-off contracts;
• Waterfall vs. agile SW development;
• Licensing Terms;
• Warranties and liability for defects in the SW;
• Problematic provisions – experience from practice;

Structuring business to the US :

• How best to enter the US market;
• Where can I get some help/information/grants?
• What is the tax and administrative burden?
• How to choose the right lawyer and accountant?
• How to get into the investors/funds horizon?
• In which state are the best conditions to enter the US market?

Tax optimization for digital and IT companies :

• Holding structure – owner protection;
• Patent Box and Supercomputing – how some IT companies do not have to pay income tax in Slovakia;
• Other tax and levy types and practical experience;
• When is tax optimisation already a criminal offence;

Schwarz system :

• Tax-tax implications and calculations;
• Impact on employees’ social insurance benefits (maternity, pension, sick leave,…);
• What impact does the change to a sole trader’s trade have on a sole trader’s pension?
• Analysis of court decisions that have dealt with the topic;
• Practice of tax administrations and labour inspectorates;
• Criminal liability;
• Setting up contracts with contractors;

Relevant financial ratios when a company is sold or an investor enters :

• What is of interest to the investor or the buyer in accounting?
• Risks associated with incorrect accounting;
• Capitalization of the company;
• Transaction Experience;

Many topics and many questions from conference participants. Companies were particularly interested in topics around ESOPs, tax optimizations or company sales. However, many attendees stayed until the end to hear the current practice in connection with the so-called In the meantime, there was a lot of interest in the practice of the shvarc system (i.e. the employment of freelancers).

We received a lot of positive feedback on the content and organisation of the conference. We are therefore very pleased that after the conference on setting up investment funds, this conference was also a success.

If you are interested in this topic, please do not hesitate to contact us.

Článok Conference on legal and tax optimization for technology companies je zobrazený ako prvý na Highgate.

Slovak law currently regulates the issue of employee shares only in the case of a simple joint stock company. However, even this is only a framework, which gives companies a relatively high degree of flexibility in setting up their employee share plans. Although the commercial law does not expressly provide for the issuance of shares to employees in the case of limited liability companies, the issuance of employee shares is not only legally possible but also common in Slovakia. In our experience, statistically, employee shares are even more prevalent in LLCs. The issuance of company shares is also not limited to company employees. Many growing startups, especially in the IT sector, operate “on invoice” and can also motivate their key suppliers with shares in the company and its profits.

Slovak companies have basically three options (although there are different functional derivatives) as to what form of shareholding to offer to their key employees and suppliers. The first one is a direct transfer of the business share or shares of the company. In practice, the firm will thus transfer a portion of the shares in the firm to an employee or supplier for a nominal contribution. However, in our practice, we see this option as rather an exception.

The second option is to grant a right (option) to acquire the company’s shares in the future, at a predetermined, usually below-market price. In this case, the employee or contractor can decide whether to exercise this right in the future and ask the company to transfer an agreed number of shares.

A third option is to issue shadow shares or shares in the company. Unlike the first two options, in this case the employee or contractor does not become a registered shareholder or partner of the company. By virtue of a contract with the company, the employee or contractor receives a “shadow” share in the company’s business, which grants him or her the same de facto range of property rights and benefits as standard shareholders and partners. In some respects, shadow shares resemble a silent partnership, which may have tax benefits. However, the terms of their issue are considerably more flexible. In our experience, shadow shares are the most common form of employee remuneration in Slovak companies today, especially for small start-ups. In practice, the acquisition of employee shares, options or shadow shares is usually linked to the fulfilment of agreed conditions. Most often, these include staying in the company for an agreed period of time, or achieving the planned revenues, or employees completing specific tasks.

Regardless of which of the three options a company chooses, it is crucial that not only a lawyer but also a tax advisor is already sitting in the boardroom when planning the issuance of employee stock. Ideally in one person. Employee stock issuance, especially with the third option, need not be particularly complicated. Issuing them, however, brings with it a number of tax and levy burdens on the part of the employee or contractor, as well as the company, which can add a rather bitter flavour to the benefit.

In more than one case that landed on our office desk, the owners did not give much thought to the tax burden of employee stock. Or they left that thinking to the standard tax adviser who had not thought about the alternative options the law offers that can lead to avoiding high taxes and levies. That is to say, even a legally sophisticated employee stock issuance plan is a ticking time bomb without tax analysis. Generally, a tax advisor is naturally unable to legally evaluate whether proposed alternative solutions are legally sound. The logic behind this is logical. After all, the tax advisor may not be familiar with other legal options for setting up employee stock and option plans, and even if he or she is familiar with them, he or she cannot by default evaluate whether they are legitimate or illegitimate tax optimizations. And the lawyer, in turn, is naturally unfamiliar with the tax aspects of such alternative arrangements.

Here at Highgate Group, we have not only lawyers with extensive experience in employee share legal setup under one roof, but also tax lawyers, tax advisor and accountants with whom we can tailor the proposed structure so that it does not cause excessive tax and levy burdens for companies and employees. Therefore, we can cover the issues related to the issuance of employee shares not only legally, but also tax and accounting under one roof, which is more convenient for the client than dealing with these two complements through two different addresses (lawyer and tax advisor) in the best case, or not at all in the worst case. We are therefore able to analyse and create legal and tax complex structures that ensure our clients’ employee actions remain truly beneficial.

Článok Employee shares and interests.
A benefit that doesn’t have to have a bitter taste. je zobrazený ako prvý na Highgate.

Článok Employees can also earn profits in the form of shares or options je zobrazený ako prvý na Highgate.