The Czech Republic Supreme Administrative Court elaborated on the burden of proof in transfer pricing and incentive regimes cases in a ruling which concluded that a taxpayer did not qualify for incentive regime tax relief because it failed to prove it priced transactions with its subsidiary at arms length, writes KPMG in a November 17 report. For discussion, see KPMG.
The Czech Tax Administration has announced new reporting obligations applicable to companies that engage in transactions with related parties located in foreign countries, reports PwC in an August 11 newsletter. For details, see PwC.
For discussion of the October 15 decision, 9 Afs 57/2015 – 120, see, EY.
The requirements for the entry into force of the treaty between Luxembourg and the Czech Republic, signed March 5, 2013, were met on July 31 and the treaty entered into force as of that date, the Luxembourg tax authority has announced. Release (in French), A Memorial – No. 162 of August 14, page A 2501 (in French)
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