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…
Proving inter-company services and determining transfer prices
Almost all multinational groups of companies ensure part of their activities on a central basis and re-invoice shared services to group companies. This often involves significant amounts. It is therefore not surprising that tax administrators have…
GFD guideline on research and development
Case law of the Czech Supreme Administrative Court confirms that a flawless research and development project represents a necessary precondition for claiming a research and development deduction in a tax return. The General Financial Directorate …
VAT: Do you know you should have known?
In their data boxes, selected VAT payers have recently received a notice whose purpose at first sight is not entirely clear. In the Notice on Taking Adequate Measures the tax administrator lists recommended preventive measures.
A clear path towards interest on retained deductions
The taxpayer’s entitlement to interest on long-retained excess deductions has been repeatedly confirmed by the Supreme Administrative Court (SAC), despite the financial administration’s…
CJEU again on conditions of exempt intra-community supplies of goods
In its ruling regarding intra-community supplies of goods, the Court of Justice of the European Union (CJEU) again confirmed the widely discussed possibility to attribute transport just to one supply within a chain of supplies. The ruling also…
“Perfect” documentation does not automatically guarantee deductibility for tax purposes
In its recent judgment (file no. 7 Afs 330/2016), the Supreme Administrative Court (SAC) again held that even an accounting document free of any formal deficiencies and containing all essential elements does not prove on its own that the declared…
VAT Act amendment lets tax administrators cancel VAT group registrations earlier
The amendment to the VAT Act effective from 1 July 2017 accelerates the process of terminating VAT group registrations. Where the registration is terminated ex officio, the registration terminates at the moment the tax administrator’s decision…
Not only personal income tax under Supreme Audit Office’s scrutiny
From June 2016 to this spring, the Supreme Audit Office (SAO) examined personal income tax administration and its examination outcomes do not spare the financial …
SAC: Partial payment orders may not be issued
According to the Supreme Administrative Court, the Tax Procedure Rules do not allow the issuance of a payment order for only a portion of tax. This means that VAT payers from whom the tax administrators retain excess deductions sometimes amounting…
Stricter conditions for tax deductibility of expenses?
Some rulings by the Supreme Administrative Court (SAC) have surprising outcomes and de facto narrow the space for recognising expenses as tax-deductible by requiring proof that that a service was received from a specific supplier.
Increasingly restrictive measures to secure tax collection
The tax authorities have recently adopted increasingly restrictive measures to collect as much tax as possible. One of these measures is the extended application of securing orders and their subsequent enforcement within a very short time. This,…