How to respond to inaction by tax administrator?
Proceedings before the tax authorities often take longer than taxpayers would like. However, like all proceedings before public administration authorities, these proceedings are subject…
Ground-breaking judgement: vacation compensation to be included in R&D allowance
The Regional Court in Hradec Králové issued judgement No. 31 Af 23/2016-76, dealing with tax allowances for research and development (R&D allowance). The judgment is truly ground-breaking, as it rejects the standpoint so far taken by the tax
Controversial amendment to Tax Procedure Code published in Collection of Laws
In early June, a long-awaited and widely discussed amendment to the Tax Procedure Code was published in the Collection of Laws. The amendment expands the information duty towards tax administrators and implements – with a few months’ delay – the EU…
When does the super-gross salary concept apply to benefits from third persons?
The Regional Court in Hradec Králové has recently dealt with the income tax implications of employee benefits provided by third persons. The court’s decision affects the determination of employees’ super-gross wages.
What to expect in a transfer pricing inspection?
Not too long ago, transfer pricing was an issue tax administrators preferred to avoid, as their knowledge was limited in this respect. These times are over.
Dependent agent permanent establishment
The Regional Court in České Budejovice held that if an agent’s activity forms a separate and essential part of a non-resident taxpayer’s activity, it gives rise to the taxpayer’s permanent establishment in the Czech Republic. The activity does not…
New rules of liability for unpaid VAT according to SAC
The Supreme Administrative Court has specified the conditions of a supply recipient’s liability for VAT unpaid by the supplier: a payment to a foreign account cannot automatically give rise to liability.
SAC: Tax deductibility of expenses requires providing evidence about real supplier
In its two recent decisions, the Supreme Administrative Court (SAC) again concluded that legal entities claiming tax deductible expenses must document and prove circumstances under which these expenses were incurred, as well as provide information…