Initial situation
The accounting value recorded on a non-cash contribution does not automatically answer the tax question that matters on a later sale: what amount can be recognised as the asset's tax basis against sale proceeds? The company needed to distinguish the accounting valuation from the tax basis created under the applicable non-cash contribution regime. Getting that distinction wrong could materially change the expected taxable gain and therefore the economics of the transaction.
Our solution
We analysed the tax treatment of the original non-cash contribution and mapped the relevant statutory rules to the contemplated disposal. Because the issue turned on the interaction between the contribution regime and the later sale, we sought written methodological guidance from the Slovak tax administration rather than relying only on an internal interpretation. The resulting position was then used to reconcile the accounting carrying amount with the tax basis relevant on disposal and to identify the amount that should feed into transaction-level tax modelling.
Result
Management obtained a documented tax position before executing the sale, improving the reliability of its gain calculation, tax forecast and pricing decisions. The written methodological support also reduced interpretation risk around a technically unusual transaction and created a stronger file for future tax compliance or review.
