The Supreme Administrative Court (SAC), regarding case 8 Afs 189/2020-127, ruled against the tax authority’s claim that the taxpayer’s rental payments to affiliated advertising agencies for advertising space at football stadiums and a golf course were not at arm’s length.
The court concluded that the tax authority’s pronouncement was based on a hypothetical theory where the taxpayer could have paid a lower rental amount rather than on rational reasoning and economic experience.
Regarding case No. 8 Afs 274/2022, the SAC determined that the statutory interest rate on retained Value-Added Tax (VAT) deductions for the period from 2017 to 2020, set at 2% plus the Czech National Bank (CNB) repo rate, was consistent with EU law.
