Tax & Legal Update
R&D allowances under TREND programme
The Technology Agency of the Czech Republic has announced the 12th call to participate in the TREND programme focusing on industrial research and experimental development.
Supreme Administrative Court defends taxpayer’s acquisition structure
The Supreme Administrative Court rejected the tax administration's view that the purchase of a share in a corporation financed by a loan and the subsequent merger to transfer the loan to the newly acquired operating entity constituted an abuse of…
New way of reporting employees posted to the Czech Republic
The Ministry of Labour and Social Affairs has introduced new rules for the notification of the posting of workers in the Czech Republic within the framework of the transnational provision of services. The rules are effective from 1 July 2024 and…
Creditor protection under amendment to Company Conversions Act
On 19 July 2024, a major amendment to the Company Conversions Act (No. 162/2024 Coll.) will enter into effect. In this article, we summarise the changes concerning the protection of creditors and persons participating in the conversion and the…
Obligations under deposit-refund system for PET bottles and cans
Not all PET bottles thrown away in yellow bins are recycled. The mandatory charging of deposits on them should help in this respect. The Ministry of the Environment has published a draft amendment to the Packaging Act. Below we summarise the impact…
Generous subsidies for industries under EU ETS scheme
The State Environmental Fund of the Czech Republic has announced ENERG ETS No. 1/2024, a new call under the Modernisation Fund focusing on the modernisation of energy sources and production or processing facilities in industries under the EU ETS…
Changes to excise duties from 2025
The government has approved a draft amendment to the Excise Duty Act, which introduces several key changes aimed to reduce the administrative burden for taxpayers, increase legal certainty on the market for selected products, and increase the…
CJEU on fixed establishment for VAT purposes
In case C 533/22 SC Adient Ltd & Co. KG, the CJEU confirmed its earlier conclusions regarding the origination of a fixed establishment for VAT purposes. In the present case, as in cases C 232/22 Cabot Plastics and C 333/20 Berlin Chemie, the court…
Pillar Two: Further administrative guidance released
The OECD's Inclusive Framework has issued its fourth administrative guidance on the implementation of the model global minimum tax rules and information on the process of recognising the qualified status of domestic top-up tax.
Current developments on Pillar One
The OECD has published additional guidance on setting arm’s-length prices of marketing and distribution activities (Amount B) in low-capacity countries (jurisdictions with limited resources and data). The timing of the signing of the multilateral…
Selected foreigners no longer need work permit from July
The amendment to the Employment Act among other things extended the scope of exemptions from foreigners’ obligation to have a relevant permit to work in the Czech Republic: the category ‘citizens of selected countries’ was added. The government has…