The Tax Administrator


A New Transfer Pricing Guidance and the Czech Translation of the OECD Guidelines

The General Financial Directorate (the “GFD”) issued new Guidance D-34 on the application of international standards to the taxation of related party transactions. This guidance replaces existing Guidance D-332. Together with the new guidance, the Czech translation of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017 Edition) was published in the Financial Bulletin of the Ministry of Finance no. 5/2019. 

18. 6. 2019

When do Businesses become Entitled to Interest Paid by the Tax Administrator

Businesses often find themselves in a situation where they become entitled to interest as a result of the tax administrator’s actions or negligence. However, in practice, we often come across cases where the tax administrator does not pay the interest to the taxpayer at all or pays an amount that is lower than the one to which it is entitled by law or based on the administrative courts’ judicature. When should the entitlement to interest be claimed then? 

23. 5. 2019

Use of the guide value in determining the real estate acquisition tax base

For the purpose of determining the real estate acquisition tax base, a taxpayer has the possibility to choose either the price determined by an expert valuation or the so-called guide value (“směrná hodnota”) as the comparative tax value. The Financial Administration has so far argued that the taxpayer can no longer change the selected option once the tax return is submitted, for example by filing an additional tax return. However, the Municipal Court in Prague has now expressed the view that the taxpayer may change its decision until the tax is assessed. 

13. 2. 2019