The greatest corporate tax risk, or transfer pricing is not about prices only

Wednesday, October 24, 2018

First international  transfer pricing conference organised by IFA ČR together with KDP ČR took place on 16th October 2018. 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.

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 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.           

We believe that organising the conference was fully in line with the IFA ČR's strategic objective to create a platform for meetings of representatives of public administration, academy and practice with a focus on the conceptual development of tax law, including awareness and education with an emphasis of international tax law and its interaction with the Czech legal environment. Lets hope that this conference was first, but not the last.

Yours IFA Czech Republic