Tax report required by the bank to provide financing focusing on the identification of tax risks related to real estate sale transactions executed by the borrower

One of our Clients operating in the real estate development market (borrower), who was in the process of obtaining financing, asked us to prepare a tax report required by the bank to provide financing. The Client is the parent company in a corporate group which buys land, sets up special purpose vehicles and sells the land to those entities, which use them to carry out land development projects. The purpose of the tax report was to identify risks related to the gratuitous or partially gratuitous provision of consideration resulting from real estate sale transactions executed by the Client with the price paid 5 years after the sale. 

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