Austria, Czech Republic Poland and Hungary
As discussed in Part 2, a founder seller may be requested to "rollover" part of their shareholding in the target company to shares and/or loan notes of equivalent value in the new structure.
- Where you receive shares in the new structure for the disposal of shares in the target company it may – under specific circumstances – be feasible for Austrian tax resident founders/senior managers to "rollover" any existing shares in the target company in an (at least preliminary) tax-neutral manner within either a pure domestic or an EU/EEA context (for more details, please refer to Part 2, Section 1 Private Equity-Rollover and Reinvestment).
Czech Republic
As discussed in Part 2, a founder seller may be requested to "rollover" part of their shareholding in the target company to shares and/or loan notes of equivalent value in the new structure (for more details, please refer to Part 2, Section 1 Private Equity-Rollover and Reinvestment).
Poland
As discussed in Part 2, a founder seller may be requested to "rollover" part of their shareholding in the target company to shares and/or loan notes of equivalent value in the new structure.
- Where you receive shares in the new structure for the disposal of shares in the target company it may – under specific circumstances – be feasible for Polish tax resident founders/senior managers to "rollover" any existing shares in the target company in an (at least preliminary) tax-neutral manner (for more details, please refer to Part 2, Section 1 Private Equity-Rollover and Reinvestment).
Hungary
As discussed in Part 2, a founder seller may be requested to "rollover" part of their shareholding in the target company to shares and/or loan notes of equivalent value in the new structure.
When shares in a new corporate structure are received in exchange for shares held in a target company, it may, under certain conditions, be possible for Hungarian tax residents to benefit from a preliminary tax-neutral rollover. This treatment may apply in both domestic and EU/EEA contexts where the transaction qualifies as a preferential share exchange under Hungarian tax law. In such cases, unrealised capital gains may be deferred, and taxpayers may elect to pay the resulting tax liability in five annual instalments. This deferral is subject to anti-abuse provisions, particularly in line with EU/EEA compliance requirements. If any of the statutory conditions are breached—such as the sale of the contributed shares, or the failure to pay an instalment – the deferred tax becomes immediately payable, unless otherwise exempted under Hungarian law (for more details, please refer to Part 2, Section 1 Private Equity-Rollover and Reinvestment).
Slovakia
As discussed in Part 2, a founder seller may be requested to "rollover" part of their shareholding in the target company to shares and/or loan notes of equivalent value in the new structure.
- Where you receive shares in the new structure for the disposal of shares in the target company it may – under specific circumstances – be feasible for Slovakian tax resident founders/senior managers to "rollover" any existing shares in the target company in an (at least preliminary) tax-neutral manner within either a pure domestic or an EU/EEA context (for more details, please refer to Part 2, Section 1 Private Equity-Rollover and Reinvestment).