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Solutions

International taxation

Legal regulation of international taxation should be monitored not only by companies with activities abroad, but also by many entities that are only active in the Czech Republic.

We have goodexperience and we are able to perform an assessment of the relevant risks but also opportunities both from the perspective of Czech national legislation as well as double taxation treaties. Thanks to our global network we also cooperate with colleagues from the respective countries and we are ready to assess these questions as needed also with respect to foreign tax regulations in almost all foreign jurisdictions.

We will help you resolve (not just) these questions

  • Does your company pay any income abroad (e.g. dividends, interest, licence fees, rent) that can be subject to withholding tax in the Czech Republic?
  • Does your company receive income from abroad that can be subject to taxes there?
  • Does your company use the exemption from withholding tax or at least a reduction of its rate in the above cases?
  • Does your company deduct the so-called tax securement when required by valid legislation?
  • Has a foreign member of your group (e.g. parent company) sold shares/participation in a Czech company or real estate located in the Czech Republic,  or does the member receive income from the lease of such real estate (which could lead to the tax liability in the Czech Republic)?
  • Are the premises of your company used by the staff of a foreign company (which could lead to the creation of a Czech permanent establishment of this foreign company)?
  • Has your company concluded a contract that could lead to the creation of a Czech permanent establishment of a foreign contractual partner (which could lead to a notification obligation for your company with respect to the tax authorities)?
  • Are you considering establishing a holding structure that would help you simplify the structure of the company’s portfolio, or do you already have a holding and you would like to be certain that the structure set-up does not represent a tax risk?
  • Would you like to know whether international tax initiatives (BEPS, ATAD) have an impact on the operation of your company?
  • Are you planning a project abroad and would like to know what the tax impacts and requirements are relevant in that country?

Comprehensive services tailored to fit your needs

We will assess the risks of origination of a permanent establishment of a foreign company, at the premises of your company or elsewhere, and suggest measures to minimise this risk.

We are able to fully adapt the services to your long-term or immediate needs. We will perform a general analysis of a case typical for your company, down to a detailed examination of specific contracts (especially licence or loan contracts) with respect to withholding tax and an individualised assessment of specific payments.

Contact

Marek Romancov

Marek Romancov

Partner

Since 1997, Marek has been intensively involved in the field of transfer pricing. During his practice, he participated in the implementation of many projects in the Czech Republic and CE region. He fo... More

Jaroslav Škvrna

Jaroslav Škvrna

Partner

Jaroslav is a Partner in the Tax & Legal function in Deloitte Czech Republic. He has more than 20 years of client experience gained at Deloitte. His professional career has focused on various tax matt... More