In the first article, we focus on the amendment to the Top-Act Tax Act, which brings, in particular, an extension of deadlines for filing the information return and tax return, as well as a number of technical adjustments responding to OECD Administrative Guidance.
The following article provides a practical view on VAT deduction adjustments for overdue liabilities according to the new explanatory information published by the General Financial Directorate at the beginning of July.
In the third contribution, we focus on the current Supreme Administrative Court ruling on the inclusion of material costs in the cost base for calculating arm’s length profit markup in transfer pricing and its potential impact on manufacturing companies.
The next article highlights a recent decision of the Municipal Court in Prague in the matter of false self-employment (so – called Schwarz System), which confirms the strict interpretation of labour inspectorates in cases where cooperation between companies and self-employed individuals exhibits the characteristics of dependent work.
Finally, we bring you an article by our Italian colleague on the strategic aspects of transfer pricing adjustments at the end of the financial year, which is also relevant for Czech corporations operating within local or international business groups.
We wish you an enjoyable read and a pleasant autumn season.
In the first half of August this year, the long-awaited adoption of the government proposal for a law amending the Accounting Act, the Auditors Act, and the Top-Up Tax Act was approved. The enacted legislation was published in the Collection of Laws on September 2, 2025, and became effective on September 3, 2025. This article focuses on the amended provisions of Act No. 416/2023 Coll., on Top-Up Tax...
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.
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...
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,...
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