Overview of the Czech Transfer Pricing Regulations

Transfer pricing rules were introduced in Czech tax legislation in about 1993, strictly along the OECD principles and rules.

There is no legal obligation on the taxpayer to undertake a transfer pricing analysis. However, tax authorities exert pressure on taxpayers through other means to prompt them to show that their relations with related parties are at arm’s length.

Taxpayers are offered the opportunity voluntarily to submit an analysis of their business relations and prices vis à vis related parties and apply for a tax ruling. As it is a somewhat cumbersome and costly procedure, only a few companies have applied up to now.

Related case law on transfer pricing is scarce, but what there is reveals victories for both the tax authorities and taxpayers in particular cases.

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