Although the causes and expected results of the changes taking place are obvious to the owners and managers of the company, they may not be equally clear to the other stakeholders.
For this reason, the justification of the motives and objectives of the actions performed will improve cooperation with the stakeholders, both internal (including employees) and external ones (e.g. contractors, in particular banks and state institutions).
Furthermore, in light of applicable tax laws, an economic rationale for reorganisation activities is required by fiscal audit authorities. Successive amendments to the Corporate Income Tax Law (Art. 22c, Art. 10 sec. 4a) and amendments to the Tax Code (Art. 119a-119zf; so-called tax avoidance clause) transfer the burden of proof of the economic viability of the reorganisation changes to the entrepreneur.
In the case of tax audits, the taxpayer will be required to demonstrate that the course of action taken was not intended as taxation evasion, but was motivated by economic considerations.