Tax News – Summer 2020
We have already informed you in our previous articles about the forthcoming changes, which include so-called implementation package amending several legal regulations due to the implementation of EU tax laws. I…
The statute of limitations cannot exceed ten years, not even in the case of tax loss
In May, we informed you about a ground-breaking ruling of the Supreme Administrative Court which rejected the tax administration’s practice of extending the statute of limitations by so-called tax loss chaining…
Reporting obligation under DAC VI: The Czech Republic will use the option to postpone deadlines to early 2021
The process of reporting cross-border arrangements was supposed to start on 1 July 2020. However, the Council of the European Union has currently approved a proposal to provide EU member states with an option t…
Current Developments in the Legislative Process of the Income Tax Act
The legislative process in the field of Act No. 586/1992 Coll., on Income Taxes, as amended (hereinafter referred to as "ITA"), is very rapid, its development is difficult to predict and, moreover, the individu…
Retrospective Utilisation of a Tax Loss – Approved Version
Following a rapid development in the proposed amendment to Act No. 586/1992 Coll., on Income Taxes, as amended (the “Income Taxes Act “), as regards retrospective utilisation of a tax loss, the government bill …
Latest Update on the Reporting Obligation for Cross-Border Arrangements (DAC VI)
Based on the Directive on Administrative Cooperation in the Field of Taxation (“DAC VI”), EU member states, including the Czech Republic, should introduce the obligation of economic entities to report to taxati…
The Supreme Administrative Court Rejected Tax Loss Chaining
The Supreme Administrative Court ruled in favour of taxpayers when it rejected the tax administration’s practice of extending the statute of limitations by so-called tax loss chaining.
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…
Supreme Administrative Court Case Law: Tax Treatment of Assignment of Receivables Arising from Contractual Sanctions
The Supreme Administrative Court (“SAC”) has issued a ruling (10 Afs 171/2019-51) dealing with the question of how to tax assigned receivables from contractual sanctions arising in the current period or that ar…