Tax Newsletter - Archive
Forvis Mazars Tax View - archive of tax articles
Amendment to the Top-Up Tax Act
In the first half of August this year, the long-awaited adoption of the government proposal for a law amending the Accounting Act, the Auditors Act, and the Top-Up Tax Act was approved. The enacted legislation was published in the Collection of Laws on September 2, 2025, and became effective on September 3, 2025. This article focuses on the amended provisions of Act No. 416/2023 Coll., on Top-Up Tax for Large Multinational Groups and Large Domestic Groups (hereinafter referred to as the “Top-Up Tax Act”).
Schwarz System under Scrutiny Again: Supreme Administrative Court Confirms Strict Approach
The Supreme Administrative Court of the Czech Republic (hereinafter “SAC”) has once again taken a firm stance against illegal freelance arrangements that, in reality, meet the criteria of an employment relationship. In its recent ruling (8 Ads 65/2024-53), the Court made it clear: contractual form is not enough—what matters is the actual substance of the working relationship.
Flexible Amendment to the Labour Code
On 29 April 2025, the so-called “flexi amendment” to the Labour Code (Act No. 262/2006 Coll., as amended) was published in the Collection of Laws. It represents the most extensive change to labour law in recent years. Most of its provisions will take effect on 1 June 2025.
Taxation of Employee Stock and Option Plans: Overview of the Current Situation
Several significant legislative changes have occurred in recent months regarding the taxation of employee stock and option plans (hereinafter "ESOP"). We would like to provide you with an overview of the current state of this issue and help you navigate it.
Transfer Prices – The Arm's Length Principle in the Context of Parent Company Influence
As part of corporate income tax returns, many of you have already provided or will soon provide your tax administrator with basic information on intra-group transactions. This, in conjunction with financial statements and reports on related parties, is pivotal information used by tax administrators when selecting taxpayers for transfer pricing audits.
Extension of the Deadline for the Tax Assessment when an Additional Tax Return is filed
In this article, we would like to highlight a recent discussion by the Coordination Committee between the Chamber of Tax Advisers of the Czech Republic and the General Financial Directorate (hereinafter referred to as “CC”) regarding the extension of the deadline for tax assessment under Act No. 280/2009 Coll., the Tax Code (hereinafter referred to as “Tax Code”), when an additional tax return is filed.
Tax exemption of income from crypto-asset sales
On 15 February, the amendment to Act No. 32/2025 Coll. came into effect, amending various laws related to the implementation of EU regulations on financial market digitalization and sustainability financing. It includes an amendment to the Income Tax Act that will exempt certain personal income from crypto-asset transfers from taxation.
Limitation of income tax exemption from sales of securities and shares from 1 January 2025
As part of the consolidation package approved at the end of 2023, an amendment to the Income Tax Act was adopted, which introduced significant changes to the taxation of personal income from sales of securities and shares in the business corporations, effective from 1 January 2025. While the existing time test conditions remain unchanged, a new limit for tax exemption of such income was introduced at CZK 40 million per taxpayer per tax period.
Secondment of executives from the parent company and its impact on the transfer pricing methodology
Recently, corporate groups have increasingly addressed the question of how to manage individual subsidiaries effectively while avoiding transfer pricing risks. A recent judgment of the Regional Court in Hradec Králové (31 Af 3/2024 – 77) shows that the secondment of employees of the parent company to the management of a subsidiary can have significant implications for the transfer pricing assessment.
Deduction of VAT on fuel purchases using fuel cards
It seems it could perhaps finally be said that after more than twenty years, we have relative clarity as to whether and under what conditions a VAT payer can claim a VAT deduction when purchasing fuel using fuel cards.