On 12 September 2023, the European Commission published a proposal for a transfer pricing directive (the “EU Directive”) as part of the so-called “BEFIT” package. In addition to introducing a common EU-wide inc…
Intragroup transactions and transfer pricing are continuously on the radar of tax administrations around the world, including the Czech Financial Administration. Therefore, tax audits with focus on transactions…
In December 2021, the European Union adopted an amendment to Directive 2013/34/EU concerning the rules for the disclosure of income tax information (so-called public country-by-country reporting or public CbCR)…
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…
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…
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.
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…
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…
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…
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…