WALLESS requested positive binding tax ruling for the client

WALLESS counsel Priit Raudsepp assisted a huge player in real-estate sector in getting a positive binding tax ruling. The case required out-of-the-box thinking. The ruling provides substantially lower effective tax rate while avoiding having burdensome cross-border structuring. The ruling creates a precedent as the period for which it is binding exceeds earlier periods by almost 4 times. Additionally, the tax authorities agreed to apply the substance-over-form principle in favour of the taxpayer.