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VAT regime for transfer pricing settlements – is clarification finally coming? Value-added tax

In light of the recently published opinion of the Advocate General of the CJEU in Case C-726/23, we are revisiting the issue of the VAT treatment of profit...

Jiří Jakoubek
Richard Knobloch
| 7 min read | April 22, 2025
Costs of consultancy from related parties in a group Transfer pricing

On 16 May 2023, the Supreme Administrative Court ruled on the tax deductibility of consultancy costs provided to a company by companies that are part of an...

Jiří Jakoubek
| 5 min read | July 25, 2023
Slovak transfer pricing legislation and its changes from 1 January 2023 Transfer pricing

Due to the large number of relationships and transactions between Czech and Slovak tax entities, we provide basic information on the amended transfer pricing...

Jiří Jakoubek
| 8 min read | June 13, 2023
Case law on transfer pricing: profit mark-up on value added vs. total cost Transfer pricing

In a recent judgment, the Regional Court in Brno dealt with a dispute between a taxpayer and the tax administration regarding the choice of a profitability...

Jiří Jakoubek
| 5 min read | May 16, 2023
Abolition of the exemption of income from the sale of securities and shares above CZK 40 million Tax Audit

We would like to draw attention to one of the key issues that has been announced as part of the recovery package, but has not received as much media attention.

Jiří Jakoubek
Zuzana Kalincová
| 4 min read | May 15, 2023
Recovery of state finances as proposed by the government – Who will benefit from it? Corporate income tax

At a press conference on 11 May 2023, the Czech government presented an extensive proposal for a public finance recovery package aimed at halting the...

Jiří Jakoubek
Zuzana Kalincová
| 6 min read | May 12, 2023
Impact of a price regulation of the ministry of healthcare on transfer pricing for the sale of medicinal products and foodstuffs intended for special medical purposes Transfer pricing

We would like to inform you of the potential implications of a price regulation [1] of the of the ministry of healthcare, which came into force at the...

Jiří Jakoubek
| 6 min read | March 9, 2023
The ARGO-HYTOS 2 Afs 66/2021 judgment in the light of the circumstances of this case Tax Audit

The Supreme Administrative Court (SAC) issued a judgment annulling the decision of the Regional Court (RC) confirming the tax assessment on grounds of...

Jiří Jakoubek
Zuzana Kalincová
| 9 min read | March 7, 2023
The Supreme Administrative Court has reprimanded the tax administrator for an unreviewable transfer pricing analysis Transfer pricing

The Supreme Administrative Court (SAC) has issued a judgment annulling the decision of a regional court confirming additional tax assessment on grounds of...

Jiří Jakoubek
Zuzana Kalincová
| 4 min read | December 21, 2022
EU will have a 15% minimum tax from 2024 International Taxes Advisory

On 22 December 2021, the European Commission presented its further proposals against tax evasion and the erosion of corporate taxpayers’ tax bases (BEPS 2.0...

Jiří Jakoubek
Petr Němec
| 3 min read | December 14, 2022
From the case-law: Cash pooling under tax control Transfer pricing

On 27 October 2022, the Supreme Administrative Court (SAC) issued a judgment on the issue of the normal price in the case of cash pooling, including the tax...

Jiří Jakoubek
| 4 min read | December 6, 2022
Windfall tax proposal approved by the Chamber of Deputies Conflict in Ukraine

On Friday 4 November 2022, after several hours of debates, the Chamber of Deputies approved the Windfall tax proposal in its third reading. The second...

Tomáš Brabenec
Jiří Jakoubek
Jaroslav Foltýn
| 3 min read | November 8, 2022
Windfall tax - we present a draft amendment Conflict in Ukraine

As a result of the negative effects of the war in Ukraine, the prices of gas, electricity and petroleum products have increased enormously, which in turn...

Tomáš Brabenec
Jiří Jakoubek
| 19 min read | October 24, 2022
Federal Financial Court comments on the setting of transfer prices for intra-group financing Transfer pricing

As we pointed out at the seminar on tax news and developments, in the transfer pricing area, the perception and concept of intra-group financing rules have...

Jiří Jakoubek
| 3 min read | November 29, 2021
The effects of the Covid-19 pandemic on transfer pricing and the attitude of the tax administrator Transfer pricing

The worldwide pandemic crisis has an influence on transfer pricing as well. Many mutually connected companies are dealing with a decrease in demand,...

Jiří Jakoubek
| 8 min read | May 18, 2021