Corporate Tax 2010 - BMR Advisors
Corporate Tax 2010 - BMR Advisors
Corporate Tax 2010 - BMR Advisors
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Cipcic-Bragadin<br />
Croatia<br />
Croatia<br />
7 Anti-avoidance<br />
7.1 How does Croatia address the issue of preventing tax<br />
avoidance For example, is there a general anti-avoidance<br />
rule or a disclosure rule imposing a requirement to<br />
disclose avoidance schemes in advance of the company’s<br />
tax return being submitted<br />
In general, all relevant facts should be disclosed to the relevant<br />
authority e.g. obtaining more than 50% of equity in a foreign<br />
company or if the entity is a connected party to another company<br />
etc. that might have impact on the tax liability. However, the exact<br />
information in the tax proceeding could be withheld if they might<br />
lead to, among other cases, to self incrimination. The burden of<br />
proof for the facts used to determine tax liability lies on the relevant<br />
authority, and for those facts that could lower tax liability, to the<br />
relevant party.<br />
Silvije Cipcic-Bragadin<br />
Cipcic-Bragadin<br />
Kala 7, Supetar<br />
Island of Brac<br />
Croatia<br />
Tel: +385 98 467 466<br />
Fax: +385 21 631 822<br />
Email: silvije@c-b.hr<br />
URL: www.c-b.hr<br />
Silvije is a partner in Cipcic-Bragadin mainly in charge for firm’s<br />
corporate, banking and finance and TMC work. He is also<br />
responsible for relationship with international clients. He was<br />
educated in Zagreb and in London at the College of Law of England<br />
and Wales. He holds diploma in English corporate and commercial<br />
law. During his education in London he was seconded to Deutsche<br />
Bank’s corporate finance team. In 2004 he founded Croatian PE<br />
association and in 2008. he initiated a founding of Croatian<br />
business angel network. He is honorary member of both<br />
associations. During 2008 he was collaborating with DLA Piper<br />
Croatia where he was a Head of <strong>Corporate</strong> group. Silvije is a pioneer<br />
in PE and VC financing and frequent speaker on various PE<br />
investment conferences and workshops. He was one of the authors<br />
of publication called SME Finance Manual covering legal aspects of<br />
private equity and venture capital.<br />
Hrvoje Cipcic-Bragadin<br />
Cipcic-Bragadin<br />
Masarykova 15<br />
Zagreb<br />
Croatia<br />
Tel: +385 14 814 219<br />
Fax: +385 14 871 949<br />
Email: hrvoje@c-b.hr<br />
URL: www.c-b.hr<br />
Hrvoje is partner in charge of Cipcic-Bragadin’s vast real estate<br />
practice as well as and restructuring and insolvency practice<br />
including litigation practice. He was also a registered bankruptcy<br />
receiver for number of years. Hrvoje is a relationship manager for<br />
local public clients such as the city of Zagreb, municipality of Bol,<br />
municipality of Selca etc. and has been involved in some of the<br />
biggest real estate transactions and privatisation processes. He is<br />
also very active in public procurement work. Hrvoje has a Croatian<br />
education but worked with many law firms prior to joining Cipcic-<br />
Bragadin. Speaks fluently English and German and a little bit of<br />
Russian and he’s a member of International Chamber of Commerce,<br />
American Chamber of Commerce in Croatia, German-Croatian<br />
Chamber of Commerce and Industry.<br />
Founded in 1928, Cipcic-Bragadin is one of the leading law firms in Croatia recognised in many international legal<br />
guides such as Chambers and Partners, IFLR1000, PLC which Lawyer, Legal 500 etc.<br />
Our goal is to provide a first class advice according to international standards. That is why many of Cipcic-Bragadin’s<br />
clients are leading international companies such as the Bank of America, Bank of America Securities, EBRD, Deutsche<br />
Bank, Fortis bank, Merill Lynch, Credit Suisse, Komercni bank, Mid-Bau gruppe, Parkridge Holding, Stemcor holding,<br />
Lenovo, Yahoo!, Lexmark, Discovery Networks EMEA, RCI Europe, Aston Martin etc. That is also why Cipcic-Bragadin<br />
frequently collaborates with the leading international law firms.<br />
Our expertise include real estate law, corporate law (private equity, M&A) tax, employment and public procurement law,<br />
banking and finance law, technology, media and commercial law, dispute resolution law, restructuring and bankruptcy<br />
law.<br />
Cipcic-Bragadin currently operates a group of 11 offices around Croatia providing a seamless service throughout<br />
Croatia.<br />
58<br />
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ICLG TO: CORPORATE TAX <strong>2010</strong><br />
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