Posts by author: Tomáš Kubiš

Tax 

European Commission issues draft transfer pricing directive

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… 

Tax 

Transfer pricing: judgment on the including the depreciation of valuation difference in the cost base

The Regional Court in Hradec Králové issued judgment No. 31 Af 21/2022-99 on transfer pricing, where it confirmed the tax administrator’s view that when a valuation difference arises in an intra-group restructu… 

Tax 

OECD: Manuals on advance pricing arrangements and handling of mutual agreement procedures

Avoiding tax disputes is the fundamental principle of tax certainty. The growing number of Advance Pricing Agreements (APAs) is successfully contributing to the increasing tax certainty and predictability of ta…