Financial Administration

Tax 

Information of the General Financial Directorate on the effects of the Covid-19 pandemic on transfer prices

On 31 March 2021, the General Financial Directorate issued information on the effects of the Covid-19 pandemic on transfer prices (the “Information”) pursuant to recommendations of the OECD of December 2020 (the “OECD Guidance”). The General Financial Directorate notes that the OECD Guidance does not involve a special recommendation beyond the currently applicable Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (the “Guidelines”), it rather focuses on the application of the arm’s length principle in the context of the pandemic. Below, we summarise the opinion of the finance administration on certain issues which the General Financial Directorate discusses in more detail in its Information. Therefore, it can be assumed that the finance administration will proceed in line with the Information when examining the periods affected by the pandemic, although this does not constitute a change in the relating legislation. Together with the Information, the General Financial Directorate published the translation of the OECD Guidance into Czech. 

26. 4. 2021