Czech Republic



Do your intra-group interest rates comply with the arm’s length principle?

In the context of inspections carried out by the financial administration which focus on transfer pricing, we have registered an increasing demand for examining or ensuring compliance of interest rates on related-party credits and loans with the arm’s length principle. How are the interest rates determined in such cases? The terms of loans and credits […]

Tax risks in real estate transactions, or when machinery is part of a structure

The new Civil Code effective since 2014 has introduced a new rule under which fixed machinery can become part of a structure. This leaves most machinery and structure owners rather cold, but only until the property is to be sold. A real estate sale transaction gives rise to a tax obligation to pay real estate […]

Bank requirements for expert assessment related to financial assistance

The recent increase in transaction activity in the market and in acquisition financing has prompted financing banks to require an assessment of fair conditions under which financial assistance is given, as laid down in Section 200(1)(a) and Section 311(a) of the Companies Act. In acquisition financing, the parent company (the buyer) very often makes use […]

High-quality expert opinion as evidence in a lawsuit

In recent years, we have seen an increasing demand for expert opinions for litigation purposes. Practice has shown that a well-prepared expert opinion that the expert can defend in the proceedings constitutes a material basis for claiming damages and for the court’s decision. A major change in the practice of expert opinions prepared for lawsuits […]

Real estate value upon spin-off

In connection with company restructuring, in recent years we have seen companies dividing the manufacturing activities from asset management. Real estate spin-off into a separate entity brings numerous advantages, the biggest being: more efficient company management processes and lower costs easier bank financing increased asset liquidity assets become more attractive for potential sale of the […]

Expert opinions – highly effective tool for transfer pricing defence

The tax authorities have recently launched a systematic collection of information on related-party transactions. This is aimed at making audits of transfer pricing methodology (arm’s length prices charged to transactions with related parties) more efficient and extensive. In this respect, numerous questions arise as to how transfer prices should be defended and whether transfer pricing […]

Planning to restructure your business?

When deciding to carry out restructuring, numerous companies choose the beginning of a new fiscal year as the date of the restructuring, that is, typically 1 January. Given that many companies are now preparing to go ahead, we wish to summarise the key milestones of company restructuring from a valuer’s point of view: when an […]

Ambiguity of basic valuation terms in Czech law

We wish to share with you our opinion on the definition of fundamental terms used in the preparation of expert opinions under the new Civil Code (Act No. 89/2012 Sb.) and the Companies Act (No. 90/2012 Sb.). This article focuses mainly on valuations for the purpose of transfers between related parties or in-kind contributions.

Expert opinions and real estate transfers in 2014

The beginning of the year brought a number of changes relating to new real estate legislation. Changes have quietly emerged in the taxation of real estate transfers (now real estate acquisition) as well as a new valuation decree and methods of tax assessment.

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