Tax Newsletter - Archive
Forvis Mazars Tax View - archive of tax articles
Transfer Prices – The Arm's Length Principle in the Context of Parent Company Influence
As part of corporate income tax returns, many of you have already provided or will soon provide your tax administrator with basic information on intra-group transactions. This, in conjunction with financial statements and reports on related parties, is pivotal information used by tax administrators when selecting taxpayers for transfer pricing audits.
Extension of the Deadline for the Tax Assessment when an Additional Tax Return is filed
In this article, we would like to highlight a recent discussion by the Coordination Committee between the Chamber of Tax Advisers of the Czech Republic and the General Financial Directorate (hereinafter referred to as “CC”) regarding the extension of the deadline for tax assessment under Act No. 280/2009 Coll., the Tax Code (hereinafter referred to as “Tax Code”), when an additional tax return is filed.
Tax exemption of income from crypto-asset sales
On 15 February, the amendment to Act No. 32/2025 Coll. came into effect, amending various laws related to the implementation of EU regulations on financial market digitalization and sustainability financing. It includes an amendment to the Income Tax Act that will exempt certain personal income from crypto-asset transfers from taxation.
Limitation of income tax exemption from sales of securities and shares from 1 January 2025
As part of the consolidation package approved at the end of 2023, an amendment to the Income Tax Act was adopted, which introduced significant changes to the taxation of personal income from sales of securities and shares in the business corporations, effective from 1 January 2025. While the existing time test conditions remain unchanged, a new limit for tax exemption of such income was introduced at CZK 40 million per taxpayer per tax period.
Secondment of executives from the parent company and its impact on the transfer pricing methodology
Recently, corporate groups have increasingly addressed the question of how to manage individual subsidiaries effectively while avoiding transfer pricing risks. A recent judgment of the Regional Court in Hradec Králové (31 Af 3/2024 – 77) shows that the secondment of employees of the parent company to the management of a subsidiary can have significant implications for the transfer pricing assessment.
Deduction of VAT on fuel purchases using fuel cards
It seems it could perhaps finally be said that after more than twenty years, we have relative clarity as to whether and under what conditions a VAT payer can claim a VAT deduction when purchasing fuel using fuel cards.
Payment for early termination of the contract by the customer from the VAT point of view
In this article we would like to draw your attention to a recent decision of the Court of Justice of the European Union (hereafter the ‘CJEU’) in case C-622/23 rhtb (hereafter ‘the Decision’), which dealt with the issue of the VAT treatment of payment for early termination of a contract by the client. At issue was whether the payment was subject to VAT or whether it was compensation for damages not subject to VAT.
GFD information on changes in the field of VAT from 1 January 2025
Employee Share Plans Taxation – Optional Tax Regime on the Horizon
This year has brought significant changes in the taxation of employee share and option plans (hereinafter "ESOP"). The new rules effective from January 2024 (more in our article HERE) have caused numerous complications in practice. However, better times are ahead - on 24 October 2024, a parliamentary amendment was introduced as part of the amendment to the Act on the Provision of Childcare Services in Children's Groups, which aims to significantly simplify the situation.
Increased Tax Deduction Limit For Donations Extended Until 2026
The increased limit for tax deductions on donations, originally introduced as a temporary arrangement, will remain in effect until 2026. The proposal currently in the Chamber of Deputies maintains the maximum limit for deduction of donations at 30% of the tax base.