Tax & Legal Update
SAC: filing additional tax return a preferred option to initiating tax inspection
Where the tax authority has reason to expect that additional tax will be assessed, taxpayers must be given a chance to correct their error by filing an additional tax return. Typically, these are cases where the conclusions of a single tax…
Not granting personal data subject’s request is an administrative decision
The Supreme Administrative Court (SAC) dealt with the admissibility of an action for protection against unlawful infringement by an administrative body in a case where a personal data subject was not satisfied with how their request under the…
SAC: Involvement in tax fraud must always be proved by tax administrator
The Supreme Administrative Court (SAC) dealt with a case in which the tax administrator denied a taxpayer’s entitlement to deduction of VAT on received taxable supplies, claiming that the taxpayer knew or should have known that they had been…
OECD’s discussion draft on the transfer pricing of financial transactions
The discussion draft provides guidance on the pricing of common intra-group financial transactions, such as loans, cash pools, hedging transactions and guarantees.
Brexit: What happens if UK leaves the EU with no deal?
In mid-July, the UK government published more than a hundred-page-long document called the UK-EU Future Relationship White Paper, providing information on how the relationships between the UK and the EU should look like with respect to the economy,…
American import duties: a trade war and accumulating WTO complaints
A few months have passed since the USA introduced duties on the imports of steel, aluminium, solar panels and washing machines. Currently, no end is in sight for one of the modern history’s greatest trade conflicts. The number of import duties is…
To what extent may the rights of members of limited liability companies be…
The Chamber of Deputies is currently discussing an amendment to the Act on Corporations. Below we present a summary of the amendment’s changes relating to the types of ownership interests in limited liability companies.
Quicker construction of motorways and other key infrastructure, at last?
An amendment to the Act on Accelerating the Construction of Transport, Water, Energy and Electronic Communication Infrastructure (No. 169/2018 Coll.) entered into effect on 31 August 2018. It primarily deals with the backbone motorway network, main…
New double taxation treaty with Korea introducing substantial changes
In Seoul in January 2018, the Czech Republic and Korea signed a double taxation treaty, replacing a document from 1992 no longer meeting current tax and economic requirements. Among other things, the new treaty changes the taxation of paid dividends…
Services received – how to prove their tax deductibility?
Do you receive services from intracompany or external providers whose actual substance is uncertain or whose benefit for your company is doubtful? The tax authority may no longer regard the mere provision of such a service’s tax document as…