Advised a group of companies of the energy sector

Our team has advised a group of companies of the energy sector in the dispute with the Tax Authorities over the transfer of losses between members of the same group and the reduction of Corporate Income Tax burden. The issues involved were the application of the substance over form principle for the benefit of the taxpayer, the width of the application of exceptions provided in the tax laws and the interpretation of the true intentions of the legislative bodies upon creation of tax exemptions.