The number of tax audits focused on transfer pricing in the Czech Republic and the resulting tax adjustments have increased rapidly because of Czech Tax Administration’s systematic risk assessments. These risk assessments are successively used to pick taxpayers for transfer pricing audits. The Tax Administration is applying the disclosure reporting of related party transactions as part of a risk analysis if selecting taxpayers for a transfer pricing audit. The recent audits focus on companies in ‘high risk’ types from the transfer pricing perspective and specific transactions identified through the disclosure reporting. Companies that stated tax losses or received investment incentives as a tax relief become main targets for transfer pricing audits. The usual inter-company transactions include business restructuring, licence fees, management or service fees and interest or other types of financial payments. Although transfer pricing documentation is still optional, is highly recommended and generally expected to be prepared and submitted during the tax audit.
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