BEPS 2.0: progress and setbacks

The preparation of BEPS 2.0, new rules for the taxation of the digital economy, has made some progress. Preliminary consensus has been reached on Pillar 1, defining a new rule according to which income will be taxed in the state of sale even if the…

DAC7 at last? European Commission targets digital platforms and sharing services

With the implementation of DAC6 underway in Europe, the European Commission has now submitted an initiative that may bring the seventh revision of the Directive on Administrative Cooperation in the Field of Taxation. It focuses on digital and shared…

OECD releases Transfer Pricing Guidance on Financial Transactions

The OECD released the long-awaited final version of a report on the pricing of related party financial transactions, which is part of BEPS Action Plans 4, 8-10 and will be implemented into the OECD Transfer Pricing Guidelines. The report focuses on…

Brexit from a Czech immigration law perspective

With the last day of January, the never-ending story of Brexit finally ended. The law implementing the withdrawal agreement was passed by the Parliament of the United Kingdom of Great Britain and Northern Ireland early this year and signed by Queen…

Application of beneficial ownership and anti-abuse principles in the EU 

Courts across the EU have been inspired by the so-called Danish judgements of the Court of Justice of the EU, and so some national courts’ decisions on the taxation of dividends and interest payments received by holdings have followed the beneficial…

Another extreme penalty for insufficient personal data protection

1&1 Telecom GmbH, a German mobile service operator, was fined EUR 9.6 million for the failure to implement sufficient technical and organisational measures to protect the personal data of its customers. This is one of the highest penalties ever…

Prudential requirements for dealers in securities

In December 2019, new regulations dealing with prudential requirements for dealers in securities were published in the EU Official Journal, introducing a new categorisation of dealers in securities and rules for the remuneration of their employees,…

New rules facilitating cross-border corporate mobility within EU

Two amendments to Directive (EU) 2017/1132 of the European Parliament and of the Council of 14 June 2017 on certain aspects of company law aim to harmonise and modernise EU company law and improve the application of the freedom of establishment. The…

BEPS 2.0: Revolution in international taxation on the horizon

Following up on the Base Erosion and Profit Shifting (BEPS) initiative, the OECD Secretariat published a document containing a new proposal for a unified and global approach to the taxation of the digital economy, BEPS 2.0, introducing a new method…

Due managerial care – a new perspective?

The European Union is preparing a legal regulation aiming to put the finance sector at the forefront of efforts for a greener and cleaner economy. The new regulation will promote sustainable projects that may be loss-making over long periods with…

Better protection for whistle-blowers

The EU Council adopted a directive setting the minimum rules of protection for persons reporting corporate wrongdoings. The directive is to be transposed into Czech law by May 2021.

Starbucks can celebrate – Dutch APA issues most likely resolved

The EU General Court ruled in favour of Starbucks and the Dutch authorities and annulled the European Commission’s decision on illegal state aid provided within an advanced pricing agreement. At the same time, however, the court upheld the EC’s…