Articles by: Daniel Johannes

Tax 

The Supreme Administrative Court has issued its first-ever statement on one-crown bonds

Recently, the Supreme Administrative Court was deciding for the first time on a case involving “one-crown bonds”. Surprisingly, the subject matter of the dispute did not concern the abuse of rights. The question was whether the company had proved the tax deductibility of bond interest in line with Section 24 (1) of the Income Tax Act. The Court agreed with the tax authorities on this matter and confirmed additional tax assessment. It should be pointed out that the factual circumstances of the case were specific. 

23. 6. 2021
Tax 

The Supreme Administrative Court rejected the practice of the Tax Authorities regarding the establishment of a lien on a non-finally assessed tax

The Tax Code allows the tax administrator to secure unpaid tax by establishing a lien on the property of the taxable entity. If the taxable entity fails to pay the tax secured by the lien in a proper and timely manner, there is a risk that the tax administrator may recover its claim from the property on which the lien was established. 

17. 3. 2021
Tax 

DAC 6: New Obligation to Report Certain Transactions to Taxation Authorities in Advance

The Chamber of Deputies is currently discussing the governmental draft bill implementing the directive on administrative cooperation in the field of taxation (“DAC 6”). This directive regulates the obligation of businesses to report selected cross-border transactions and other arrangements affecting corporate income tax to taxation authorities in advance. The objective of this EU regulation is to gain better insight into the use of tax regulations and prevent aggressive tax planning. 

20. 9. 2019