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Competent Authority
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for MNE and transfer pricing cases:
Mr. Michal Rohacek
Head of Direct Taxes International Cooperation Unit
General Financial Directorate
Lazarská 7, 117 22 Prague 1
Czech Republic
Tel: +42025704 4162
Fax: +42025704 3047
e-mail: michal.rohacek@ds.mfcr.cz
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Organization
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General Financial Directorate (Direct Taxes Department, Direct Taxes International Cooperation Unit)
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Scope of MAP & MAP APA
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Taxation not in accordance with the provisions of the Double tax treaties; interpretation and application of the DTA in cases which are not covered by the DTA.
Negotiation of bilateral or multilateral APAs.
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Domestic guidelines & administrative arrangements
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APA - Section 38nc of Act on Income Tax;
Guidance D-333, Communication by the Ministry of Finance in respect of binding ruling on the transfer pricing policy used in related party transactions.
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Time for filing
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Keeping with the DTA provisions. |
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Form of request
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A letter to the locally competent tax administrator (by the Czech taxpayer) or to the competent authority (by the other tax authority). |
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Documentation requirement
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No special documentation requirement, but in accord with the domestic tax law a person liable to tax must substantiate (i.e. provide documentary evidence of) all the facts which he/she is obliged to state in his/her tax return, supplementary tax return and other submissions or he/she must substantiate these facts when requested to do so by the tax administrator in the course of tax proceedings. |
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User fees
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10 000 CZK for APA |
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Tax collection / penalty / interest
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Collection by the local competent tax administrator. |
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Other dispute resolution mechanisms
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The EU Arbitration Convention for transfer pricing cases. |
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Government Website
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http://cds.mfcr.cz |
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