Ovlivňují české společnosti základ daně transakcemi se zahraničními spřízněnými osobami?
Do Czech Companies Influence Tax Base Using Intercompany Transactions?

Summary/Abstract: The article discusses the issue of base erosion and profit shifting in relation to the Czech corporate income taxpayers. We describe the basic techniques how the base erosion and profit shifting can be realized and analyze the occurrence of the base erosion in the Czech Republic. We compare the average ROE and ROA ratios for the largest Czech entities with those achieved by the largest companies in Luxembourg, Netherlands, and Switzerland as the countries are generally considered as tax havens. Malta is also included in the analysis. The main hypothesis is the conjecture that the Czech companies’ corporate income tax base is influenced by transactions with related parties mainly by using royalties and intragroup trades in goods and services i.e. through transfer pricing. As the Czech taxpayers, based on the results of analysis, achieved in 2006–2015 period lower ROE as well as ROA in comparison to the selected countries (with an exemption of Switzerland) it can be concluded that their tax base is likely influenced by aforementioned profit shifting techniques.

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