Sample matter · INV-DX-0142
Holdco s.r.o.
Holding 100% of its operating company, Opco a.s.
Day of acquisition1 Jan 2025
Earliest qualifying sale1 Jan 2027in 216 days
Planned / likely sale30 Jun 2027
Headroom+5 months
Verdict
BUILD
Exemption protects €0 tax that would otherwise leave first
The exemption · the three testsall three, at once
01
Ownership
Holdco s.r.o. holds 100% of Opco a.s. directly.
Pass
02
Time
Month 16 of 24. Earliest qualifying sale 1 Jan 2027.
On track
03
Substance
Real person, place and decisions, logged each quarter.
On track
This week · Needs your attention
▲
Month 15 overdue — 28 Mar 2026
Monitoring log, quarterly memo and governance decision. Reconstructed proof
weakens the history, close this first.
⚑
Q1 2026 memo outstanding
Tab E. Quarterly monitoring memos across the holding period.