How the situation is with documentation of transfer prices in the Czech Republic

Tax laws in the Czech Republic still do not require any payers to prepare documentation of transfer prices. However, the Ministry of Finance published information about the method of its preparation already a few years ago. Cautious companies are not hesitating to prepare documentation, and in many cases they are doing so in connection with the multinational rules of concerns.

Already for 2014, each larger company has to attach to its income tax return a special annexe documenting transactions with connected persons and entities. This is mandatory for companies that fulfil at least one of the following criteria:

• the value of total assets exceeds CZK 40 million, or net turnover exceeds CZK 80 million, or the average recounted number of employees is more than 50

and at the same time

• they have conducted any transactions with a connected person or entity based outside of the Czech Republic, or
• they have reported a loss in their tax return and have also carried out any transactions with a connected person or entity (foreign and/or domestic) or
• they are recipients of any investment incentives in the form of tax discounts and have also carried out one or more transactions with a connected person or entity, whether foreign or domestic.

KODAP advisers will be happy to provide more detailed information and assistance with preparing a tax return and/or documentation of transfer prices.

publikováno 15.01.2015