• EU introduces new system of tax dispute resolution

    October 3, 2019

    As of 1 July a new system of rules comes into force to ensure quicker and more effective resolution of tax disputes between Member States. It includes especially double taxation issues and interpretation and application of international agreements on elimination of double taxation.

    Currently there are 2000 such disputes pending in EU, out of which around 900 are over 2 years old. Double taxation occurs when two or more states claim the right to tax the same income or profit of a company or person. This is caused by mismatch between national rules of different jurisdictions or divergent interpretations of the same provisions in a bilateral tax treaty.

    Until now, there has only been a multilateral convention that gives tax authorities the possibility to submit a dispute to arbitration. The tax payer however has had no opportunity to trigger the process himself. Furthermore tax authorities haven’t been required to reach a final agreement.

  • Tax news for the year 2019

    January 8, 2019

    At the end of the last year, the Chamber of Deputies approved the so-called tax package, which amends especially the Income Tax Act, the Value Added Tax Act and the Tax Code. Most of the changes brought by the tax package will come into effect during 2019.

    Amendments to the Income Tax Act

    • limitations on the deductibility of interests from the tax base, when exceeding CZK 80 million or 30% of EBITDA, calculated for tax purposes from pre-tax tax profits, interest, depreciation and amortization
    • taxation on the transfer of property to a permanent establishment or head office abroad without change of ownership
    • taxation of controlled foreign companies (controlled foreign company – CFC rules)

  • Country by country reporting – What is it about?

    October 9, 2017

    Europe union accepted Council Directive (EU) 2016/881 of 25 May 2016 amending Directive 2011/16/EU as regards mandatory automatic exchange of information in the field of taxation. This directive is about obligation for companies from multinational groups sharing accounting and other tax information, which is called Country by country reporting (further only “CbCR”).

  • Amendment to the Act on auditors has already come into effect

    October 6, 2016

    As of October, 1st, amendment to the Act on Auditors has come into effect. The amendment applies European directive 2014/56/ effective from June 2014 which transforms the former European directive 2006/43/ES on mandatory audits of yearly and consolidated financial statements together with Regulation (EU) No 537/2014 of the European Parliament and the Council on specific requirements regarding statutory audit of public-interest entities...

  • Regulation „eIDAS“ – have you already heard about it?

    June 27, 2016

    New regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic identification and trust services for electronic transactions in the internal market becomes effective as of July 1st (also called Regulation eIDAS). The goal of the regulation is building of digital single market and creating appropriate conditions for the mutual recognition of key enablers across borders, such as electronic identification, electronic documents, electronic signatures and electronic delivery services, and for interoperable e-government services across the European Union...

  • Consumers can solve disputes by using alternative dispute resolution

    April 12, 2016

    As of 1st February 2016 it came into effect an amendment of the Consumer protection law which enables to solve disputes between consumers and sellers by using alternative dispute resolution. Sellers are obliged to inform consumers that there are new ways of alternative dispute resolutions...

  • EU-Commission decides selective tax advantages for Fiat in Luxembourg and Starbucks in the Netherlands are illegal under EU state aid rules

    November 2, 2015

    The EU- Commission has concluded that selective tax advantages provided by local tax authorities for Fiat in Luxembourg and Starbucks in the Netherlands are illegal under EU state aid rules. The tax authorities issued tax rulings which artificially lowered the tax paid by the company...

  • OECD aims to restrict shifting of corporate profit into low/no tax environments

    October 26, 2015

    G20 finance ministers adopted OECD international tax reform to restrain tax evasion. The reform says that huge multinational corporate businesses will pay taxes in the state where profit is earned therefore they could not shift profits artificially in to low or no tax environments where no business activity occurs. According to OECD researches in 2013 the governments’ revenue losses amounts from USD 100 to 240 billion annually thanks to profit shifting into tax advantageous areas...

  • New directive to support fight against legalization of revenues from criminal activity

    October 26, 2015

    European Parliament adopted as of May 2015 a new Directive (EU) 2015/849 of the European Parliament and of the Council on the prevention of the use of the financial system for the purposes of money laundering or terrorist financing. The aim is to increase transparency of ownership structures of legal persons and trust funds. The most important changes are the establishment of central register of final owners of legal persons and trust funds, tightened control of politically exposed persons and unification of penalties at community level. The entrepreneurs can receive a cash payment in the maximum amount of 10 000 euro compared to former 15 000 euro. Using tax revenues from tax criminal activity will be considered as money laundry.

  • Electronic records of sales

    October 19, 2015

    As of June 3, 2015 the government approved a new law introducing a system of electronic records of cash sales of goods and services („e-tržby“, e-sales or EET in the Czech language) which should come into effect in the middle of 2016. If the Parliament adopts the law it will be created a new way of immediate communication between businessman and the Financial Administration of the Czech Republic...