GFD: Assessing transfer prices and determining a permanent establishment’s tax base, revisited
In November, the General Financial Directorate published new Instruction D – 32, dealing with a binding assessment of the manner in which the price agreed between related parties and the tax base of a tax non-resident relating to activities…
Transfer price checks also in personal income tax inspections
Transfer prices between related parties remain a priority of tax administrators’ inspection activities. As much as the general public believes that this only concerns corporate entities and cross-border transactions, the recent Supreme…
Reporting cross-border transactions
On 5 June 2018, DAC 6 was published in the EU Official Journal. It introduces a new reporting duty and automated information exchange for cross-border arrangements motivated by obtaining a tax advantage.
CJEU: effect of subsequent modifications of transfer prices on customs value of goods
The Court of Justice of the European Union (CJEU) has issued its first ruling on the effect of subsequent adjustments to transfer prices on the customs value of goods imported to the EU. According to the judgement, even if a group’s transfer
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…
2017 OECD Transfer Pricing Guidelines
On 10 July 2017, the long awaited 2017 OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2017 Transfer
Latest news - April 2017
Last month’s tax and legal news in a few sentences.
Survey: Czech tax environment not supportive of business
Almost two thirds of finance managers do not consider the Czech tax environment favourable for business activities and more than half of them view the changes made in the last two or three years as negative. In their opinion, the most negative is…