What is new in real estate taxation?
As part of the consolidation package, the Real Estate Tax Act has also been amended. Most of the changes will already be relevant for the upcoming year 2024. Although many of the changes will be reflected autom…
Proposal to change the taxation of employee stocks under ESOP
A new regulation on the taxation of employee stocks was submitted on 24 October 2023 within draft amendment No. 3452 to the Government Bill amending certain acts in relation to the development of the financial …
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…
Restrictive interpretation for the application of the 5% tax rate for SICAV sub-funds
In its recent judgments, the Municipal Court in Prague has supported the interpretation of the tax administration and rejected the application of the 5% corporate income tax rate to sub-funds of companies with …
Consolidation Package: Proposed changes to employee benefits
As we have already informed you, the draft Consolidation Package entered the legislative process on 30 June 2023. The external comment procedure led to some changes to employee benefits, with further adjustment…
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…
The Regional Court ruled on the issue of the beneficial owner of royalties
We bring you a recent judgment of the Regional Court in Brno (no. 29 Af 62/2018), which considered the issue of the beneficial owner of income arising from the royalties paid abroad. Recently, beneficial owners…
Cross-border work in the EU: social security and the new framework agreement
The EU Administrative Commission has approved a new framework agreement on social security coordination, which will come into force on 1 July 2023. The agreement responds to the changing labour market, in parti…
Non-compliance with electronic filing of tax returns exceptionally without penalties
The tax authorities will not impose penalties for non-compliance with the electronic method of filing tax returns. The reason is the extension of the range of persons for whom a data box has been established as…