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 …
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 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.
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…
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…
The Ministry of Finance of the Czech Republic prepared another government measure to mitigate the impacts of the crisis caused by the COVID-19 outbreak. The change concerns Act No. 586/1992 Coll., on Income Tax…
The Court of Justice of the European Union (CJEU) issued its decision on 27 February 2020 in the AURES case (C-405/18) referred by the Czech Supreme Administrative Court in 2018, concluding that tax losses incu…
The regional court in Hradec Králové reviewed the legitimacy of calculating the amount of deductions for research and development (“R&D”) by means of ‘calculated expenses’. The court ruled that the Income T…
With the forthcoming deadline for filing the corporate income tax return, we summarise below several areas which may cause complications in practice.