Support in Obtaining an Advance Tax Ruling

It is critically important for businesses to conduct operations and transactions in full compliance with tax legislation, but this is not always easy. Companies often face uncertainty in the process of their activities and questions arise – for example, how will the tax authority assess a particular operation, what risks arise and what obligations may be imposed on you within the framework of this operation, whether you correctly interpret ambiguous provisions of the legislation, whether you meet the requirements for using tax benefits, etc.

In such cases, requesting a preliminary ruling gives you the opportunity to familiarize yourself with the tax authority’s assessment in advance regarding the reporting rules or obligations to be fulfilled under the Tax and Customs Code of Georgia and be guided by their explanations.

Loialté offers full support at every stage of your relationship with the Revenue Service in requesting an advance ruling. Our team ensures that your operations based on the advance ruling are carried out transparently and without additional tax burden, in a predictable environment.

What does Loialté’s advance ruling request support service include?

Within the scope of the offered services:

  • Transaction analysis and risk assessment – ​​we will study the content of specific transactions and determine the tax risks associated with them;
  • Tax position formulation – we present our position regarding the tax liabilities to be accrued within the scope of the transaction under consideration (as well as views and recommendations related to the optimal tax treatment of future transactions);
  • Preparation and submission of documentation – we present the factual circumstances and our reasoned position regarding the issue under consideration, along with questions, in writing to the Revenue Service for decision;
  • Communication and representation – we will fully participate in the preliminary ruling process, from the submission of the application to the issuance of the preliminary ruling (or receipt of an official response), which also includes active participation in discussions and deliberations with the Revenue Service in the best interests of the taxpayer;
  • Strategic recommendations – We offer legal and financial advice on how to plan operations to minimize tax liabilities while complying with the law.

A preliminary ruling is an official explanation by the Revenue Service regarding the legal assessment of a taxpayer ‘s specific operation or transaction .

If your company is carrying out or planning operations whose tax consequences are not clearly defined, or the existing legislation does not provide a clear interpretation, the Loialté team is ready to help you – both by providing qualified tax advice and recommendations, and by supporting you in the process of obtaining an advance ruling. An advance ruling issued at your request will create a legal guarantee that you will not be subject to additional tax obligations in the future in connection with the operation in question.

If you act in accordance with a preliminary ruling, it is not permissible for the supervisory/law enforcement authority to make a decision contrary to the preliminary ruling and to impose a tax and/or sanction.

Loialté is the largest provider of the so-called Growth Hubs project of the “Produce in Georgia” agency, and business entities that meet the criteria set by the program can benefit from co-financing of up to 10,000 GEL in the following areas:

  • Finance and Accounting;
  • Taxes;
  • Legal services;
  • Business plan, strategic planning and business modeling;
  • HR services.

Additional information about the program can be found at the link .

When using the advance ruling request support service, Loialté will provide you with experienced tax auditors and consultants who have many years of experience working in both the private and public sectors (including the Revenue Service), and are insured for professional liability by a leading insurance company.

Our team ensures that your operations are carried out transparently, without additional tax burdens, and in a predictable environment based on a preliminary decision.

At the same time, Loialté holds an ISO 9001:2015 certificate in the tax field, which confirms the high quality of our services and compliance with international standards.

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