The General Financial Directorate picked on the transfer pricing
sphere again. In order to harmonize the procedures for applying
international standards in the taxation between so-called related
parties, the General Financial Directories issued a new Instruction
D-34. At the same time as the new Instruction, the Czech version of
the OECD Transfer Pricing Guidelines for Multinational Enterprises
and Tax Administrations was published in the Financial Bulletin of the Ministry of Finance
No. 5/2019, as amended in 2017.
Although the Instructions D are not legally binding guidelines
for tax payers, they bind the tax authorities and they must act
within their intentions. The aim of the Instruction D-34 is to
increase the legal certainty in determining the tax base affected
by transactions between related parties and in the area of
so-called transfer prices. In comparison with its predecessor, the
Instruction D-332, the new Instruction focuses more deeply on the
following
