Czech Republic: Next wave of transfer pricing inspections

Czech Rep: Next wave of transfer pricing inspections

The “specialized tax authority” has posted on its website information about another wave of transfer pricing inspections that it is planning to conduct, beginning as early as this month (June 2015).

Related content

Similar information previously appeared on the tax authority’s website in mid-February, and according to information reported by taxpayers, those transfer pricing inspections actually did take place shortly thereafter.

The recent information from the “specialized tax authority” primarily draws attention to internal analyses and criteria used in selecting taxpayers for tax inspection.

  • Two-thirds of inspections will be based on a finding that “not all doubt of the tax administrator has been removed or not all means of proof have been provided.”
  • The remaining one-third is to be completed shortly.

KPMG observation

Transfer pricing is often a complicated matter, and a black-and-white perception of things in this context can often be misleading. Before giving an answer to the tax authority, taxpayers may want to consider certain broad questions—such as, what direction are the tax authority’s questions really headed? Also, properly prepared transfer pricing documentation handed over to the tax authority may actually transfer the burden of proof to the tax authority.

For more information, contact a KPMG Global Transfer Pricing Services professional in the Czech Republic:

Daniel Szmaragowski+420 222 123 841

Tomáš Drašar+420 222 123 582

Or contact a tax professional with KPMG's Global Transfer Pricing Services.

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