Page 17 - CEE Tax Guide 2024
P. 17

Czech Republic  mass transport of passengers. The supply of books is VAT-  VAT payers are obliged to submit VAT returns, EC Sales Lists
           exempt subject to certain conditions. VAT-exempt services
                                                               and Control Statements (detailed evidence for selected
           include financial and insurance services, the transfer   transactions) on a monthly or quarterly basis (depending
           of buildings/apartments/non-residential premises (from   on the status of the VAT payer).
           5 years following the building approval), renting of real   Other indirect taxes include excise duties (on mineral oils,
           estate, mail services, radio and TV services, education   spirits, beer, wine, and tobacco products) and an energy
 Mazars, s.r.o.  services, and medical and social care services.  tax (on natural gas, electricity, and solid fuels).
 Pod Dráhou 1637/4,170 00 Praha 7 –
 Česká republika   VAT options in                              Personal income tax / Social security system
 Phone: (+420) 224 835 730         Applicable / limits
 www.mazars.cz  Czech Republic                                 Personal income tax is applied at progressive rates
            Distance selling     EU threshold – EUR 10,000/year OSS   of 15% and 23% on all types of income (employment,
                                       system applicable       self-employment, rental incomes, capital gains, interest)
            Call-off stock                  ü                  with exemptions of certain types to dividends and interest
            VAT group registration  ü  – only for Czech legal entities  or director fees paid to non-residents, which are taxed
                                                               at a flat rate of only 15%.
            Cash accounting – yearly
 Corporate taxes and other direct taxes     Investment incentives in a form of tax relief (tax holiday)   amount in EUR (approx.)  No  Income from employment and self-employment
 are available for up to 10 taxable periods.                   activities is subject to social security and health
 The general corporate income tax (CIT) rate is 21%. A CIT   Import VAT deferment  ü  insurance contributions. In the case of employment, the
 rate of 5% applies to basic investment funds and 0%   A special corporate tax referred to as a windfall tax applies   Construction works, waste, gold, selected   employee’s contribution is equal to 7.1% (social security)
 applies to pension funds.  to selected taxpayers in the fossil fuel sector and energy   cereals and industrial crops, cell phones,   and 4.5% (health insurance). For the employer, these
 Tax losses may be carried forward for up to 5 taxable   sector and to banks in the calendar years 2023-2025.   integrated circuits, notebooks, tablets,   are equal to 24.8% and 9%, respectively. Social security
                                 videogame consoles, used real estate,
 periods. Tax losses may also be carried back for 2 taxable   The windfall tax rate is 60% and is applied on a specifically   Local reverse charge  supply of natural gas and electricity   contributions are not paid on income exceeding the
 periods. The maximum amount that may be carried back   calculated tax base.   to traders, provision of telecommunication   maximum assessment base (CZK 2,110,416). The example
                                   services to traders, outplacement
 from one taxable period is limited to CZK 30 million   Generally, a withholding tax of 15% applies to dividends,   of construction workers, and immovable   below shows the employer’s and employee’s costs in the
 (approx. EUR 1.2 million).  royalties, interest, and to income originating in the Czech   property in forced insolvency sales.  case of the minimum wage and average wage in the
 R&D tax allowance of up to 110% of eligible R&D costs can   Republic. Tax rates may be reduced by double tax treaty   Option for taxation  private sector.
 be claimed as a tax base deduction.
 (DTT). The Czech Republic has a wide international treaty   ü  – only to Czech VAT payers for the
 Thin capitalization rules apply – financial expenses related   network with over 90 DTTs concluded. If there is no DTT   letting of real estate  performance of economic activities
 to credits, loans, and other instruments from related   or agreement for the exchange of information in place, the   supply of used real estate  ü  (5-year time test)
 parties that exceed four times the equity (six times for   payments are subject to a 35% withholding tax.  VAT registration   Approx. EUR 83,000/ year –
 banks and insurance companies) are not tax-deductible.  Tax exemption applies to dividend distributions, provided   threshold  only for Czech based legal entities.
 that certain conditions are met. Similar rules apply
 The EU Anti-Tax Avoidance Directive (ATAD) applies -   to tax exemption on capital gains from the sale of shares
 Limitation of tax deductibility of exceeding borrowing   in subsidiaries.
 costs; CFC rules; Exit taxation; Hybrid mismatch rules.
 In line with the EU Interest and Royalty Directive, the tax                                Average wage
 exemption on interest and royalty payments also applies   Wage related taxes in Czech Republic  Minimum wage  in private sector
 Transfer pricing in Czech Republic   when approved by the tax authority.
            Exchange rate CZK/EUR                                                   24.71  in EUR  in CZK  in EUR  in CZK
 Arm's length principle   ü  Since 1993  When certain conditions are met, the transactions that are
 generally subject to withholding tax but are thus exempt          765       18,900          1,779       43,967
 Since 2006 (scope   from tax must still be reported to the tax authority.
 Documentation liability  ü  of documentation is only   Total wage cost   1,023  133.80%    2,380     133.80%
 recommended)  Road tax is imposed on selected heavy trucks and trailers.  Social security contribution - employer   190  24.80%   441  24.80%
 APA  ü  Since 2006  A real estate tax applies to land and buildings, with tax   Health insurance - employer   69  9.00%   160  9.00%
 Country-by-Country   From FY 2016  rates generally depending on the type of property, while   Gross salary   765  100.00%   1,779  100.00%
 liability  ü  the final amount of tax may also be influenced by local
 rates (applied by local authorities).  Personal income tax before standard tax deduction*    115  15.00%   267  15.00%
 The recommended scope
 Master file-local file   of the TP documentation   There is no real estate transfer tax.  Personal income tax after standard tax deduction**   10   162
 (OECD BEPS 13)   ü  corresponds to the OECD   Employees' contributions   89  11.60%          206      11.60%
 applicable  VAT and other indirect taxes
 Guidelines.  Net salary                                           666      87.13%           1,411     79.30%
 Penalty  For 2024, the standard VAT rate is 21%. The reduced   * 15% tax rate is applied to gross salary up to annual income of EUR 64,040 (or EUR 5,337 monthly), income above is taxed at 23%.
 VAT rate of 12% is applicable, for example, on foodstuffs   ** Each individual is entitled to deduct a lump sum of CZK 2,570 (app. EUR 105) per month from tax liability (so called “standard tax deduction”).
 lack of documentation  No  –  and additives usually intended for food preparation,
 20% on tax underpayment   products used as food supplements or substitutes, tap
  tax shortage  ü  or 1% of decreased tax loss   water, feed for animals, seeds, plants, medicines, medical
 + late payment interest  devices meeting certain conditions, construction works
 Direct or indirect control   on residential housing, accommodation, catering services
 Related parties  > 25%
 or personally related.  except serving beverages other than tap water and specific   Pavel Klein
 Low value-added services:   beverages (such as milk, soya milk, milk- and soya-milk   Partner, Head of Tax Services
 Safe harbors  ü  3%–7% mark-up.  based beverages and similar products), water distribution   Mobile: (+420) 721 461 394
 Level of attention paid by Tax   and wastewater removal, heating and cooling, magazines   E-mail: pavel.klein@mazars.cz
 Authority  9/10  and newspapers meeting certain conditions, and the

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