Posts by author: Linda Scharingerová

Tax 

SAC: The parent company must compensate the contract manufacturer for losses

The Supreme Administrative Court (“SAC”) delivered a judgment in the area of transfer pricing confirming the opinion of the Financial Administration that fellow subsidiaries of multinational groups operating in… 

Tax 

Update to the OECD Transfer Pricing Guidelines

On 20 January 2022, the Organisation for Economic Co-operation and Development (OECD) published a new version of the Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrators (“Guidelines… 

Tax 

Ruling of the German Federal Fiscal Court regarding transfer pricing rules for intragroup financing

In its recent ruling (file no. I R 4/17 published on 21 October 2021), Federal Fiscal Court (BFH) provides clarification regarding interest rate agreed within the intragroup loan financing. 

Tax 

Information of the General Financial Directorate on transfer pricing in financial transactions

On 9 August 2021, the General Financial Directorate issued information on the guidance on transfer pricing in financial transactions (the “Information”) in which the General Financial Directorate refers to Tran… 

Tax 

Transfer prices constantly on the radar of tax administration

The issue of transfer pricing is considered to be highly risky by the Czech tax administration and therefore it has been focusing on it in the long term during tax inspections. This trend is also confirmed by t… 

Tax 

Information of the General Financial Directorate on the effects of the Covid-19 pandemic on transfer prices

On 31 March 2021, the General Financial Directorate issued information on the effects of the Covid-19 pandemic on transfer prices (the “Information”) pursuant to recommendations of the OECD of December 2020 (th… 

Tax 

Recommendations of the OECD for Transfer Pricing in Relation to the Impacts of the COVID-19 Pandemic

Extraordinary economic conditions brought about by the COVID-19 pandemic and consequent responses of governments in individual countries may bring numerous practical difficulties in applying the arm’s length pr… 

Tax 

Transfer Pricing Guidance on Financial Transactions

On 11 February 2020 the Organisation for Economic Co-operation and Development (hereinafter the “OECD”) published the final version of the report “Transfer Pricing Guidance on Financial Transactions” (hereinaft… 

Tax 

GFD’s New Guidance Note on the Binding Assessment of Transfer Pricing and the Method of Determining the Tax Base for Permanent Est…

On 9 November 2018, a new guidance note, D - 32, of the General Financial Directorate (“GFD”) was published in the Financial Bulletin of the Ministry of Finance on the binding assessment of the pricing method b… 

Tax 

Demonstrating the Receipt of Intragroup Services: Are you Prepared?

A large number of Czech businesses that are part of multinational groups already have first-hand experience that the Czech tax administration’s approach has undergone a fundamental change in recent years as reg…