Abstract

When a tax advisor is giving a legal opinion regarding tax law, in each case, they should individually evaluate totality of circumstances and functions they hold in regard to certain activities – in order to verify or whether they act as an advisor. If the level of engagement of a tax advisor into implementation of an agreement bears testimony to the fact that they are only engaged in certain activities connected with implementation and do not participate in coordination of the agreement, and their role is only to help, support and give advice – in that case, as a rule, they will operate as a supporter. Defining the function held by a tax advisor in regard to a given agreement determines the scope of their responsibilities connected with providing the Chief of the National Revenue Administration with information on mandatory disclosure.