Czech Republic: Transfer prices for advertising expenses; statutory rate of interest on retained VAT deductions upheld
Reports on recent tax-related Supreme Administrative Court (SAC) decisions
Reports on recent tax-related Supreme Administrative Court (SAC) decisions
The KPMG member firm in the Czech Republic has prepared reports on recent tax-related Supreme Administrative Court (SAC) decisions (read more at the hyperlinks provided below).
- The SAC held (8 Afs 189/2020-127) that the tax authority’s assertion that rental payments made by the taxpayer to related advertising agencies for advertising space at football stadiums and a golf course were not arm’s-length must be rejected. The court found that the tax authority’s assertion was based on a hypothetical theory that the taxpayer could have paid a lower rental amount, rather than rational reasoning and economic experience. Read a May 2024 report
- The SAC held (No. 8 Afs 274/2022) that the statutory rate of interest on retained value added tax (VAT) deductions for the 2017 to 2020 period of 2% plus the Czech National Bank (CNB) repo rate was consistent with EU law. Read a May 2024 report
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