Effects of Brexit on income tax in 2021
Although the United Kingdom already left the EU as of 31 January 2020, the transition period during which the United Kingdom is still viewed as an EU member state will end on the last day of 2020. It seems unlikely that the transition period will be…
Italian Supreme Court applying beneficial ownership and abuse of right
In its July judgement, the Italian Supreme Court applied the principles formulated by the Court of Justice of the EU (CJEU) in the Danish cases clarifying certain preconditions for applying an exemption from withholding
Postponement of advance payments on income tax on dependent activities and of withholding tax
The General Financial Directorate (GFD) has published a guideline allowing payers of personal income tax on dependent activities to apply for postponement of advance payments or for…
Ministry of Finance income tax plan for 2021
2020 has just begun, but two new amendments to the Income Tax Act for 2021 are already being discussed. The ministry is planning to introduce a lump-sum
CJEU: German withholding tax on dividends paid to pension funds contrary to EU law
The Court of Justice of the EU (CJEU) issued a ground-breaking judgment concerning German withholding tax on dividends paid to foreign pension funds. According to the court, the…
Guidance on determining beneficial ownership: part two
The Court of Justice of the EU issued judgments in a number of cases dealing with beneficial ownership for EU directive purposes. The cases at issue mostly involved the application of an exemption from withholding
Changes to income tax after 2019 amendment
The long-awaited tax package entered into effect on 1 April. Legal entities will primarily have to cope with changes to withholding tax<…
Brexit to change application of withholding tax and securing of tax
The United Kingdom has been trying to reopen the negotiation of the Brexit agreement with the EU, so far without success. If the agreement is not approved by the British parliament, a no-deal Brexit appears likely. The Czech Republic has prepared…
Guidance on determining beneficial ownership
The Advocate General has recently presented her views on a number of cases pending before the Court of Justice of the EU and dealing with beneficial ownership and its interpretation for the purposes of the EU directives. These legal disputes usually…
Not only (one-crown) bonds under the financial administration’s scrutiny
In past weeks, the financial administration commenced blanket investigations in the financing area, primarily focusing on entities that issued one-crown bonds before 2013. And its coordinated investigation procedures are not only limited to…
When will Income Tax Act amendment become effective?
An amendment to the Income Tax Act, already signed by the president, is set to come into effect on the fifteenth day of its publication in the Collection of Laws. According to unofficial…
New international treaties to alter withholding tax amounts
In 2016, the Czech Republic entered into two new double-taxation treaties and several agreements on the exchange of tax…