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DAC 6 as an unlawful invasion of privacy? Opinion of the Advocate-General International Taxes Advisory

On 29 February 2024, Mr Nicholas Emiliou, Advocate General at the Court of Justice of the European Union (“CJEU”) , commented on a preliminary question...

Zuzana Kalincová
| 5 min read | April 9, 2024
New case law: Proving indirect costs at the parent company Corporate income tax

Parent companies are required to prove the costs of holding ownership interests in subsidiaries , both direct and indirect (overhead). Such costs are always...

Zuzana Kalincová
| 4 min read | October 24, 2023
Consolidation package: changes for legal entities, VAT and in other areas Consolidation package

The Chamber of Deputies has just published the approved version of Chamber Print No. 488 (hereinafter referred to as “the consolidation package”) as it...

Zuzana Kalincová
| 6 min read | October 18, 2023
Suspension of the application of the Double Taxation Treaty with Russia Conflict in Ukraine

On 29 September 2023, the Ministry of Finance of the Czech Republic issued a Notice on the Treaty on the Avoidance of Double Taxation and Prevention of...

Zuzana Kalincová
| 3 min read | October 10, 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
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
Reporting obligation under DAC 6: news and clarifications from the GFD International Taxes Advisory

The General Financial Directorate has published an addition to the frequently asked questions and answers in relation to the reporting obligation on...

Zuzana Kalincová
| 7 min read | September 13, 2022
Novelties in double taxation conventions International Taxes Advisory

On 21 June 2022, the Treaty for the Avoidance of Double Taxation in the Field of Income Taxes and the Prevention of Tax Evasion and Avoidance of Tax...

Zuzana Kalincová
| 4 min read | July 29, 2022
DEBRA proposal released International Taxes Advisory

As a result of a DEBRA initiative (Debt-equity bias reduction allowance) which aims to motivate companies to finance their investments through equity instead...

Zuzana Kalincová
| 4 min read | June 14, 2022
DEBRA on the horizon International Taxes Advisory

Last year the European Commission announced an initiative called DEBRA, i.e., Debt-equity bias reduction allowance. The purpose of this initiative is to...

Zuzana Kalincová
| 3 min read | February 22, 2022
Tax implications of Brexit from 1 January 2021 Tax & Accounting

In this article, we would like to inform you that the so-called transition period introduced on the basis of the Withdrawal Agreement between the United...

Zuzana Kalincová
| 8 min read | January 12, 2021
The DAC 6 Directive: New reporting obligation connected to significant penalties International Taxes Advisory

In this article, we would like to draw your attention to the fact that at the end of August, an act implementing Council Directive (EU) 2018/822 (the...

Zuzana Kalincová
| 6 min read | December 1, 2020
Current measures relating to the COVID-19 pandemic COVID-19

Following the information published in the previous issued of GT News, we would like to inform you about the widening of tax relief that is part of the...

Zuzana Kalincová
| 13 min read | November 3, 2020
Great liberation package and other current measures relating to the COVID-19 pandemic COVID-19

Great liberation package

Zuzana Kalincová
| 11 min read | October 20, 2020