The General Tax Directorate has released information regarding the new transfer pricing reporting requirements on its website and confirms that tax audits, the tax authorities will pay special attention to transactions with related parties and the transfer pricing arrangements in future. It also confirms that the 2014 tax returns will contain an annex concerning transactions with related parties. Taxpayers would be needed to complete the annex if one of the following criteria is satisfied:

  • The taxpayer’s assets crossed CZK 40 million;
  • the taxpayer accomplished a net revenue in excess of CZK 80 million; or
  • the taxpayer’s average number of employees exceeded 50

Taxpayers who have fulfilled one of the above criteria, would be needed to report related-party transactions where:

  • the taxpayers made transactions with non-resident related parties;
  • the taxpayers stated a tax loss and were involved in transactions with resident and non-resident related parties; or
  • the taxpayers were beneficiaries of investment incentives or tax relief, and took into transactions with resident and/or non-resident related parties.