Obtaining a positive opinion is a prerequisite for concluding a cooperation agreement.

The cooperation agreement defines:

• the detailed rights and obligations of the parties,
• the rules of cooperation, including the principles of communication, entering into tax agreements, and conducting the monitoring audit.

The conclusion of the agreement is preceded by the negotiation of its content in order to tailor its provisions to the specific nature of the given taxpayer and the level of tax risk identified within their organisation.

The subject of these negotiations includes, among other things:

• the scope and frequency of the taxpayer's fulfilment of reporting obligations,
• the determination of materiality thresholds regarding potentially contentious issues and tax benefits.