The legislation regulating transfer pricing rules is not fully specified in Czech laws and the procedures applied in practice are based on fundamental legal principles and international recommendations. The more it is important to search for unifying application practice. And this is also one of the reasons for which the Chamber of Tax Advisers of the Czech Republic (KDP ČR) and the International Fiscal Association of the Czech Republic (IFA-ČR) organised an international conference on transfer pricing on 16 October 2018 in Prague.
The conference interconnected top Czech as well as international speakers with participants not only from among tax advisers, representatives of the public and academic spheres, including students, but also representatives of firms. The conference programme offering many interesting lectures was attended by more than 140 participants from 13 countries. The interest in this conference has confirmed that the importance of the topic of transfer pricing in the era known as “post BEPS” is still growing.
Martin Janeček, Director General of the General Financial Directorate, stated in his speech: “Financial administration has introduced many measures in the field of transfer pricing and it is focused also on analytical activities with a view to finding the right procedure in connection with tax payments in the field of transfer pricing. Also, for this reason, the Financial Administration supports discussion platforms, such as the conference of the IFA ČR and the KDP ČR and deems meetings of experts and mutual communication very important.”
Petra Pospíšilová, President of the KDP ČR, emphasised importance of cooperation of the KDP ČR and the IFA ČR with a view to finding common approaches and solutions not only in the field of transfer pricing. “Transfer pricing is not any nuclear science, but it is very demanding for companies to maintain consistency in this area and to document all necessary aspects of transactions within a holding. Any forum of this type will enable all the involved parties to realise how demanding branch it is.”
“Do not underestimate the drawing up, in time and at a detailed level, of the documentation of individual transactions between related parties, including its yearly updates and including the correctly completed “List of Transactions between Related Parties”! The documentation of these transactions is the basis for trouble-free results of tax inspections. An indication for tax authorities that something is not O.K. may be, for example, also the fact that a taxpayer asks for an extension of the deadline for the delivery of documentation. On the basis of the List filled in the tax authority processes a risk analysis and the List then serves also for asking questions addressed to the taxpayer in local investigations,” says Gabriela Hrachovinová, organiser, speaker and moderator of this event in the same person.