Amendment to the Commercial Code will bring changes regarding the transfer of majority shareholding

The law amendment especially regulates the moment when the transfer of a majority shareholding in a limited liability company takes effect.

Transfer pricing in a rapidly changing environment

The current economic development has a significant impact on the functioning of many companies. The main topic of recent months is a high inflation. However, there are several other factors that affect companies' transfer pricing policies.

The Czech Supreme Court decided on invoicing of marketing services

The Supreme Administrative Court of the Czech Republic („SAC“) has published a judgment in the case of the pharmaceutical company which concerned the invoicing of marketing services. The SAC complied with the taxpayer's cassation complaint and…

What will EU Tax Reform bring to Business Taxation?

On 18 May 2021, the European Commission issued a communication on „Business Taxation in the 21st Century". The document follows up on the current discussions on international tax rules and presents its own tax agenda, which aims to continue the…

Digital tax within the EU

Taxation of the digital economy is listed as one of the priorities of the European Commission. The target is to secure just and efficient taxation of incomes of all companies operating in the EU, whereas the European Commission already stated in…

Brexit: The end of the transition period and online shopping

The coronavirus pandemic was reflected also in an increased interest in online shopping, the number of consumers who order goods from a foreign site is on the rise. Following Brexit and the end of the transition period, we come across questions…

OECD guidance on the transfer pricing implications of the COVID-19 pandemic

OECD Guidance focuses on four priority issues where the additional practical challenges posed by COVID-19 are considered most significant and provides useful discussion of the various factors that should be considered in making arm’s length pricing…

Transfer pricing adjustments can lead to tax risks

The Municipal Court in Prague confirmed the approach of the Tax Authorities who reclassified marketing services contractually rendered abroad to the consideration received from a third party that should be included in the tax base for local supply…

Exemption of capital gains in Slovakia and Austria for corporate taxpayers

The Amendment to the Slovak income tax act effective from 1 January 2018 implemented participation exemption rules exempting capital gains from taxation also to the Slovak tax legislation. Due to transitional provisions Slovak tax resident corporate…

Six main changes in the Commercial Code

Changes in the liquidation process of companies and co-operatives, introduction of the deposit for liquidation, winding-up of companies due to overdue filing of their financial statement into the Collection of Deeds or a change in the scope of data…

Lifting of administrative burden related to the transfer of agricultural land

The strict regulation on the transfer of agricultural land has been annulled by the Constitutional Court of the Slovak Republic (the “Constitutional Court”) after an almost 4 years debate on its legality. In practice, the findings of the…

“Sale and lease back” transactions: CJEU has dealt with question of obligation to adjust the initially deducted VAT

On 27 March 2019, the Court of Justice of the European Union (CJEU) released its judgment in the case C-201/18 „Mydibel SA“, concerning the adjustment of a deduction of VAT on immovable property which was subject of a sale and lease back transaction.