Tax Newsletter - Archive
Forvis Mazars Tax View - archive of tax articles
What Lies Ahead in the Area of Transfer Pricing
In early November, the newly elected government unveiled a draft policy statement, setting out its objectives for the upcoming year. One of these priorities, aimed at ensuring healthy finances, should include measures to reduce the grey economy and streamline tax collection. Alongside the widely debated reintroduction of EET 2.0, the following measures should be implemented:
Court of Justice Ruling on the Application of VAT to Factoring Fees
In its recent decision C-232/24 Kosmiro, the Court of Justice of the European Union (hereinafter as ‘the Court of Justice’) ruled on the VAT treatment of factoring fees. This is an important decision that has an impact on current practice, where remuneration for factoring services is, at least in part, commonly considered to be interest on financing provided, i.e. a financial service exempt from VAT.
When are Transfer Prices Subject to VAT?
The Court of Justice of the European Union (hereinafter as ‘the Court of Justice’) recently ruled on the application of VAT in the case of transfer prices between related parties in its decision C-726/23 Arcomet Towercranes. However, the decision has brought rather uncertainty to the area of VAT on transfer prices.
Division by Spin-Off – Clarification of Tax Implications
By an amendment to the Act on Transformations of Commercial Companies and Cooperatives, a new form of transformation of business corporations – division by spin-off – was introduced into Czech law effective from 19 July 2024.
Accompanying Law to SMER: Key Changes in the Income Tax Act
Single Monthly Employer Reporting Effective from 1 January 2026
As of 1 January 2026, Act No. 323/2025 Coll., on the Single Monthly Employer Reporting (hereinafter “SMER”), will enter into force. The new system significantly changes how payroll data are transmitted to government authorities. It will gradually replace a number of existing forms and reports, thus reducing the administrative burden in terms of the number of filings. However, the volume of reported data will not decrease substantially and, for some employers, may even increase.
Year-End Transfer Pricing Adjustments: More Than a Routine Exercise
In the ever-evolving landscape of international tax, year-end transfer pricing adjustments have become a critical touchpoint where tax, accounting, and legal risks converge. Far from being a routine exercise, they now play a central role in determining whether a group’s intercompany pricing policies can withstand regulatory scrutiny. For multinational enterprises, the way these adjustments are planned, executed, and documented can be the difference between demonstrating robust compliance or triggering disputes, double taxation, and financial penalties. What was once considered a technical formality is now a strategic moment – one that demands coordination, foresight, and cross-functional alignment.
The Schwarz System Under Scrutiny by the Courts: Recent Ruling by the Municipal Court in Prague
The Supreme Administrative Court Assessed Markup on Material Costs: What Does This Mean for Manufacturing Companies?
The judgment of the Supreme Administrative Court (hereinafter "the Court") ref. no. 1 Afs 2/2025–54 of 21 May 2025 brought a new perspective on the assessment of the arm’s length profit markup on costs. The case concerned a Czech company (contract manufacturer) that provided manufacturing services to its parent company and was remunerated for this activity on the basis of costs incurred and a profit markup. As part of this activity, the Czech company purchased material from the parent company and used them to manufacture products that it sold to independent customers.
Are You Obliged to Adjust VAT Deductions for Overdue Liabilities?
Following an amendment to the VAT Act effective 1 January 2025, which concerned the correction of VAT deduction for overdue liabilities, the General Financial Directorate disclosed explanatory information (hereinafter as 'the GFD Information') at the beginning of July 2025.