SAC paves way for assessment of additional tax on transactions with unrelated parties

The Supreme Administrative Court has opened transfer pricing’s Pandora's box by allowing tax administrators to assess additional tax based on overall profitability not just for related…

Economic turmoil also affecting transfer prices

Inflation is one of the main economic issues for 2022. The impact of high input prices and disrupted supply chains are other factors businesses must cope with. But there are also other adverse factors. The slowing economy has also revealed new…

Regional court: tax administrator erred in applying transfer pricing rules to transactions between unrelated parties

The Regional Court in Hradec Králové sided with the taxpayer against a tax administrator who, without any basis in law, treated a part of a company's transactions with independent entities as controlled transactions. The tax administrator then…

Transfer pricing: otherwise related persons and arm’s length price

The Supreme Administrative Court (SAC) has recently closed several cases dealing with the assessment of otherwise related persons - a concept from the area of transfer prices between group companies.

Germany: New transfer pricing guidelines

Transfer pricing is a hot issue at a time when all finance ministries are searching for funds to cover their exorbitant budget deficits. The German Ministry of Finance has issued new…

Transfer pricing remains under tax administrators’ scrutiny

The financial administration has published information about its tax inspections focusing on transfer prices between related parties. In 2020, tax administrators carried out 249 inspections, assessing additional corporate income tax of CZK 1.4…

Transfer pricing - comparability analysis in times of COVID-19

The unprecedented changes in the economic environment following the outbreak of COVID-19 have created unique challenges for setting prices in intra-group transactions. The correct setting or verification of transfer prices for the past year while…

OECD on loss situation due to COVID

Lower levels of demand. Disruptions to supply chains. Increases in exceptional, nonrecurring operational costs. These are the key factors which have led to a loss situation faced by many companies of multinational groups during the COVID-19 pandemic…