Transfer pricing – new addendum to Legal Entity Income Tax

Transfer pricing – new attachment to Corporate Income Tax Return

Some changes have been made to the attachment No. 12 I. of the corporate income tax return, effective from the tax year 2017.

The changes concern the following:

• more taxpayers were added to the list of those obliged to fill out the attachment. These are taxpayers as defined in paragraph 11 section 2 point (b) to (g) of Act No. 456/2011 Coll. on the Financial Administration of the Czech Republic, as amended, and subject to certain conditions. This change applies to banks, insurance companies, savings banks, investment funds, and pension companies.
• Further, line “Rent” was added to table B, and lines “Financial and Bank Guarantees – received” and “Financial and Bank Guarantees – provided” in table C. The new lines in table C shall contain only information about whether the transaction has or has not been carried out.

At the same time, it is important to note that the data in the attachment shall be expressed in thousands CZK.