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CFC Rules in the Czech Republic after the ATAD

Publication at Faculty of Law |
2018

Abstract

The aim of the article is to analyse new CFC rules that should become part of the Czech Income Tax Act. The analysis focuses on theoretical and practical knowledge gathered from other countries where these rules have been enacted for a long period of time.

The outcome of this analysis is that new CFC rules have serious flaws that render them almost useless. The article also suggests solutions of these loopholes that should make the Czech CFC rules more efficient and in accordance with their purpose, i.e. to tackle tax avoidance.