Forvis Mazars Tax View 03/2025
We bring you the spring edition of our tax newsletter. As always, we have prepared an overview of the latest tax developments that deserve your attention.
In the first article, we follow up on our previous newsletter edition and introduce the interpretation issued by the General Financial Directorate, which clarifies some key VAT changes effective from 1 January 2025.
The next two articles also focus on VAT-related topics. The first one discusses an important ruling by the Court of Justice of the European Union concerning payments for early contract termination. The second article examines the long-awaited opinion of the General Financial Directorate on VAT deduction for fuel purchases via fuel cards.
Another article highlights a significant ruling by the Regional Court in Hradec Králové regarding the secondment of managerial staff from a parent company and its impact on transfer pricing methodology. This ruling could have major implications for the tax assessment of subsidiary companies’ functional profiles.
The final two articles cover recent changes in the taxation of income from the sale of securities and crypto assets.
We trust that our articles will serve as a valuable source of information and help you navigate the latest tax legislation changes.
Enjoy reading.
Payment for early termination of the contract
In this article we would like to draw your attention to a recent decision of the Court of Justice of the European Union (hereafter the ‘CJEU’) in case C-622/23 rhtb (hereafter ‘the Decision’), which dealt with the issue of the VAT treatment of payment for early termination of a contract by the client. At issue was whether the payment was subject to VAT or whether it was compensation for damages not...
Deduction of VAT on fuel purchases
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.
Secondment of executives from the parent company
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.
Limitation of income tax exemption from sales
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...
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.
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