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Zákon o daních z příjmů přinese od 1. ledna 2027 řadu novinek, které se dotknou jak zaměstnanců, tak zaměstnavatelů. Vedle návratu některých dříve zrušených daňových úlev dochází také k významné změně koncepce zaměstnaneckých benefitů. Nová úprava mění stávající systém limitů, zavádí nové daňově zvýhodněné oblasti a přináší i specifické změny v oblasti spropitného.

In late September, the Government approved a Ministry of Finance proposal requiring oil refineries to remit a portion of extraordinary profits generated in recent months due to conditions on the crude oil market to the state. The proposal has not yet been enacted into law; it remains subject to legislative approval, and its final wording may still be subject to change.

The Financial Administration continues to pay significant attention to transfer pricing. Its 2025 annual report describes a new model for risk identification, the ongoing specialization of Financial Administration staff, and an emphasis on the actual operations of group companies.

In its judgment of February 9, 2026, case no. 57 Af 6/2025-57, the Regional Court in Plzeň addressed the transfer pricing setup of a Czech contract manufacturer that had drawn a loan from a related party.

In judgment 8 Afs 173/2024-121 of August 7, 2026, the Supreme Administrative Court (hereinafter the "SAC") dismissed the cassation appeal filed by Mountfield and upheld the conclusions of the tax administration and the regional court, according to which the company abused the law by establishing a structure related to the early settlement of its liabilities arising from the purchase of trademarks.

If you paid local VAT on purchased goods or services in any EU country in 2025 and used these supplies for your business activities, you can apply for a VAT refund.

In June, Coordination Committee contribution No. 636/25.02.26, Application of VAT to Activities under a Planning Agreement, was published, along with the conclusions of the General Financial Directorate (GFD) regarding the matter (for more details, see CONTENTS).

Are you considering establishing a VAT group (or modifying an existing one) so that it is registered effective January 1, 2027?

In late July, the Chamber of Deputies approved a bill referred to as EET 2.0. On August 19, 2026, the Senate debated the bill and returned it to the Chamber of Deputies with amendments.

Effective July 1, 2026, an amendment to Act No. 589/1992 Coll., on Social Security Contributions and State Employment Policy Contributions, enters into force, altering the rules for calculating minimum social security advance payments for self-employed persons (OSVČ) engaged in a primary activity.

Proposed Amendments to the VAT Act: Further Simplification for Trading within the European Union

The Supreme Administrative Court Broadens the Interpretation of Related Parties for Thin Capitalisation Purposes

The OECD has published a draft update to Chapter VII of the OECD Transfer Pricing Guidelines, focusing on intra-group services.

The Supreme Administrative Court (hereinafter the "SAC") judgment confirms the ongoing emphasis on assessing the economic rationality of holding structures and demonstrating their commercial justification.

The Court of Justice of the European Union ("CJEU") has handed down its highly anticipated judgment in Case C-603/24 (Stellantis Portugal). This follows the Opinion of Advocate General Juliane Kokott, which we discussed in our previous article ("Further reflections on the assessment of transfer pricing adjustments and VAT – Advocate General's Opinion in Case C-603/24 Stellantis Portugal | Grant Thornton").

The government-approved proposal for the so-called EET 2.0 plans for the return of the Electronic Registration of Sales (EET) as of January 2027, albeit in a different format than the one abolished in 2023.