Daňová křišťálová koule

In today's hundredth jubilee audio alert, we have taken a somewhat unconventional approach and will speculate on tax areas where we feel there could be a shift in the coming years—either in the form of legislative changes or a different approach from the tax administration or courts:

• Intensified scrutiny and stricter oversight of holding structures—particularly those that ultimately lead to low taxation (or non-taxation) of the underlying income flow at the final link of the structure.
• Legislative changes limiting the "untaxed" transfer of assets from the Czech Republic abroad as part of (de)mergers.
• Intensified scrutiny and stricter oversight of in-kind liquidations without taxation.
• Interpretative shifts in the area of "debt push-downs"—the current trend emphasizing the "requirement" of the bank appears to be transitional.
• Intensified scrutiny and stricter oversight of the right to deduct VAT for holdings providing services within the group—especially where there is a significant excess deduction.
• Intensified scrutiny and stricter oversight in the area of transfer pricing assessments—including the evaluation of functional and risk profiles, bases for calculating remuneration, and financing.
• Intensified scrutiny and stricter oversight of concealed labor intermediation.
• Increased pressure for online reporting of certain transactions in (almost) real-time, for example, in the context of revenue records or electronic invoicing.
• Simplification in the application of Pillar 2 rules.
• Legislative changes leading to higher taxation of high-income individuals and increased taxation of (selected) properties.
• Growing pressure and dynamic changes in the taxation rules for products with negative impacts on the environment or in the healthcare sector.

Only time will tell. We shall see. However, if you feel that any of these areas could be relevant to your company, we would be happy to share our experiences with you.

Author:

Lucie Říhová