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Czech Republic<br />

2.5 Fiscal stimulus in <strong>2015</strong><br />

<br />

<br />

<br />

<br />

<br />

2.6 Political landscape<br />

In the Czech Republic, <strong>tax</strong> <strong>policy</strong> is governed centrally by the<br />

Cabinet, with the Ministry of Finance having the k<strong>ey</strong> role and<br />

responsibilities in this area. The Ministry drafts the majority of<br />

<strong>tax</strong> laws and initiates the legislative process.<br />

<br />

<br />

become rather smooth and quick.<br />

<br />

<strong>tax</strong> re<strong>for</strong>ms to be passed, 2014 has seen a range of measures<br />

passed, with others still under negotiation.<br />

2.7 Current <strong>tax</strong> <strong>policy</strong> and <strong>tax</strong> administration<br />

leaders<br />

Tax <strong>policy</strong> leaders (interim government — will likely be<br />

<br />

• Bohuslav Sobotka, Prime Minister<br />

• Andrej Babis, Minister of Finance<br />

• <br />

and Customs<br />

Tax administration leader<br />

• <br />

2.8 K<strong>ey</strong> <strong>tax</strong> <strong>policy</strong> changes in 2014<br />

• Extensive corporate and personal income <strong>tax</strong> re<strong>for</strong>m was<br />

<br />

Code and the Act on Corporations (primarily new civil law<br />

<br />

law features, e.g., trusts).<br />

• <br />

of qualifying expenses, which is effectively a double<br />

deduction of an individual expense, and 110% deduction<br />

applicable to year-on-year increases).<br />

• Further, the abolition of inheritance and gift <strong>tax</strong>es and their<br />

integration under the income <strong>tax</strong> brought a number of<br />

changes in the area of <strong>tax</strong>ation of non-monetary income and<br />

related interpretation issues.<br />

• New transfer pricing reporting (an overview of related-party<br />

transactions) was introduced <strong>for</strong> large <strong>tax</strong>payers — on a<br />

voluntary basis in 2014 — but will become mandatory<br />

as of <strong>2015</strong> <strong>for</strong> companies meeting at least one of the<br />

following criteria: (i) their assets exceed CZK40 mil, (ii) their<br />

net revenues exceed CZK80 mil and (iii) th<strong>ey</strong> have over<br />

50 employees.<br />

• The six-month test <strong>for</strong> the exemption of income earned by<br />

an individual from the sale of securities was prolonged to a<br />

three-year term.<br />

• <br />

<br />

• The new Real Estate Tax and the new Real Estate Transfer<br />

Tax Act became effective as of 2014.<br />

2.9 Country position on OECD Base Erosion<br />

and Prot Shifting (BEPS) Action Plan<br />

• The contemplated <strong>tax</strong> law amendments are generally aligned<br />

<br />

Plan is not the k<strong>ey</strong> driver <strong>for</strong> the amendments).<br />

• There are currently no <strong>for</strong>mal public statements,<br />

consultations, legislation or working group(s) in relation<br />

to BEPS.<br />

• At this stage, the Ministry of Finance has indicated its<br />

intention to focus primarily on transfer pricing and related<br />

<br />

BEPS Action items are of greatest interest.<br />

2.10 Pending <strong>tax</strong> proposals<br />

• The Investment Incentives Act amendment is pending,<br />

which would have an impact on the <strong>tax</strong> holidays relief<br />

(reduction of the percentage from the qualifying new<br />

investment is expected).<br />

• Additional amendments to the VAT Act and real estate <strong>tax</strong><br />

are being proposed. Neither should have material impact.<br />

2.11 Consultations opened/closed<br />

• <br />

<strong>for</strong> public consultation. Private individual <strong>tax</strong>payers would be<br />

required to prove the origin of their private assets (whether<br />

acquired from <strong>tax</strong>ed income). Additional income <strong>tax</strong> and<br />

heavy penalties would be assessed if the origin is not proved.<br />

<br />

elements as the <strong>tax</strong> authorities would be effectively able to<br />

assess <strong>tax</strong> from income earned in statute-barred <strong>tax</strong> periods.<br />

Further development is expected in this area.<br />

The <strong>outlook</strong> <strong>for</strong> <strong>global</strong> <strong>tax</strong> <strong>policy</strong> in <strong>2015</strong> |<br />

69

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