Making Dispute Resolution Mechanisms More Effective – Consolidated Information on Mutual Agreement Procedures 2023

Czechia

Recent developments relating to MAP in Czechia prior to 15 August 2023

Developments relating to MAP in the tax treaty network

• On July 24, 2023, DTT with Kosovo came into force; on May 24, 2023, new DTT with UAE was signed, on May 2, 2023, DTT with Rwanda was signed.

• On February 7, 2023, DTT with Cameroon was signed; on February 3, 2023, new DTT with Sri Lanka was signed.

Other developments relating to MAP

• MAP guidance in the process of preparation

Latest Action 14 Peer Review report

22 October 2020 - https://doi.org/10.1787/b8ee5001-en

Tax treaty network of Czechia

• 96 treaties, applicable to 97 jurisdictions

• status of MLI: in force.

Table 1. State of play of Czechia’s tax treaty network

Treaties in line with the Action 14 Minimum Standard following MLI impact	Treaties where actions are ongoing to make them in line with the Action 14 Minimum Standard	Following impact/actions, remaining treaties that are not in line with Action 14 Minimum Standard
89	2	5

Source: OECD

Czechia’s MAP programme

Organisation of competent authority function

• 15 persons:

  • two head(s) of unit

  • 13 persons working on MAP cases (all of which work on other tasks as well):

    • nine persons work on attribution/allocation cases and four persons work on other cases.

• contact persons for MAP requests:

  • for other MAP cases: Václav Zíka, Head of the Division of International Taxation, Ministry of Finance, Letenská 15, 118 10 Prague 1, the Czechia / Tel: [phone] / Email: [e-mail]

  • for attribution/allocation cases: Vítězslav Kapoun, Director of the Income Taxes Department II, General Financial Directorate Lazarská 7, 117 22 Prague 1, the Czechia / Tel: [phone] / Fax: [phone] / Email: [e-mail].

Figure 1. Competent Authority Organisational Structure

Source: OECD

Table 2. Guidance on the MAP process

MAP guidance	MAP guidance in the process of being prepared	-
MAP profile	02 October 2023	https://www.oecd.org/tax/dispute/czech-republic-dispute-resolution-profile.pdf

Overview of Czechia’s MAP Statistics for 2022

Please refer to https://www.oecd.org/tax/dispute/map-statistics-czech-republic.pdf for details with respect to Czechia's MAP Statistics.

Figure 2. Cases closed in 2022

Source: OECD

Figure 3. Evolution of Czechia’s MAP caseload (2016-22)

Source: OECD

Table 3. Overview of Czechia’s MAP caseload for 2022

Inventory for year 2022	Opening Inventory 1/1/2022	Cases started	Cases Closed	End Inventory 31/12/2022
Attribution/allocation cases	30	14	6	38
Other cases	28	8	7	29
Total	58	22	13	67

Source: OECD

Table 4. Czechia’s average time to resolve MAP cases in 2022

Cases resolved in year 2022	Pre-2016 cases		Post-2015 cases		All
	Number of cases	Average time	Number of cases	Average time	Number of cases	Average time
				Start to End
Attribution / Allocation cases	1	111.95	5	13.45	6	29.87
Other cases	0	N/A	7	10.42	7	10.42
All cases	1	111.95	12	11.68	13	19.40

Source: OECD