Articles by: Tereza Petrášová

Tax 

Prepare to prove cross-border transactions

Where is the trend of tax audits for cross-border payments heading? Definitely to proving the fulfilment of the conditions for the application of preferential tax regimes, not only formally but also in practice. This is not an isolated trend. Globally, various instruments and measures of tax administrations have focused on achieving one thing in the last few years – preventing tax evasion and situations in which income is taxed in countries with lower or zero tax rates. And the easiest way to achieve this involves audits in companies, which pay the respective income abroad. 

25. 11. 2021
Tax 

In Brief from International Taxation [October 2021]

Germany will allow partnerships to tax income as corporations through corporate tax. The Finnish Supreme Administrative Court has issued a ruling regulating the rules restricting the tax deductibility of interest expenses. The European Union has included Hong Kong in the list of non-cooperative tax jurisdictions in Annex II, together with a commitment to adjust the tax exemption regime for foreign income. This and more can be found in current news from the field of international taxation. 

21. 10. 2021
Tax 

Reintroduction of exemption of non-residents’ interest income from so-called Eurobonds

On 30 September 2021, an amendment to the Banking Act was published in the Collection of Laws, which was altered during the legislative process to also include an amendment to the Income Tax Act. This amendment reintroduces the exemption of non-residents’ interest income from so-called Eurobonds, i.e. bonds issued abroad by taxpayers with registered seat in the Czech Republic effective from 1 January 2022. 

20. 10. 2021
Tax 

OECD: Implementation plan of a two-pillar solution

The OECD kept its promise and issued a Statement on 8 October 2021 involving a draft implementation plan of the two-pillar solution to address the tax challenges arising from the digitalisation and globalisation of the economy. An information brochure including answers to frequently asked questions was issued along with the Statement. The global convention was subsequently endorsed by the G20 representatives during their summit. 

20. 10. 2021
Tax 

OECD update on a two-pillar solution

The OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (i.e., BEPS Action plan) has agreed on a two-pillar solution to address challenges arising from the digitalisation and globalisation of the economy. There are couple of changes in the current version plan, e.g., Pillar One shall be designed for all MNEs companies fulfilling specific turnover and profitability criteria (see below), while in the previous version of the plan Pillar One was mainly intended for technological giants. 

21. 9. 2021
Tax 

The new EU Tax Policy Framework of the European Commission

On 18 May 2021, the European Commission (“EC”) published its long-awaited Communication on Business Taxation for the 21st Century, introducing a short-term and long-term vision for the business tax policy agenda. The proposed agenda should support Europe in recovery from the Covid-19 pandemic and secure sufficient public revenues in upcoming years. This document complements the tax Action Plan presented by the European Commission in July 2020 as part of a package for fair and simple taxation. 

18. 6. 2021