Tax, international taxation and tax disputes

A tax opinion on a significant transaction, a new operating model, or simply an assessment of the implications of the current situation is one of our most sought-after services. We analyse both the risks and the possible solutions so that your business model reflects your strategic as well as your risk profile.

What changed in 2025 and 2026

Since 1 January 2025 the standard VAT rate is 23 %, with reduced rates of 19 % and 5 %, corporate income tax of 10 % on income up to €100,000, 21 % and 24 % on income above €5 million, and a 7 % tax on dividends. Since 1 April 2025 a financial transaction tax applies under Act No. 279/2024 Coll.; from 1 January 2026 it is paid only by legal entities, as self-employed individuals were removed from the group of taxpayers. From 1 January 2026 personal income tax has four rates (19 %, 25 %, 30 % and 35 %), health contributions for the self-employed rose to 16 %, the minimum tax for companies with turnover above €5 million is €11,520, and for cars used privately as well only half of the VAT can be deducted. Platforms and crypto-asset service providers automatically report income under the DAC7 and DAC8 directives. We will assess what of this affects you and propose how to respond.

Tax opinions

For more significant transactions we prepare an opinion that takes into account both the legal and the tax consequences and gives you certainty when making decisions.

In cross-border transactions and structures we examine the impact of double-taxation treaties on the specific case and optimise existing structures from both a tax and an administrative perspective.

Permanent establishment and exchange of information

When you do business in several countries, we assess whether a permanent establishment arises for you in another state and how income is allocated between countries. We take into account the automatic exchange of information (DAC7 and DAC8) as well as the rules against profit shifting, so that your structure stands up to scrutiny both at home and abroad.

Transactions between related parties are subject to transfer-pricing rules. We prepare the documentation and set the prices so that they stand up to a tax audit.

Documentation and pricing methods

The scope of the documentation depends on the type and volume of transactions with related parties. We prepare the transfer-pricing documentation, select an appropriate pricing method and, where needed, help with a request to have the method approved by the tax authority, so that you avoid additional tax assessments and penalties during an audit.

A tax dispute is won or lost already during the audit. What you say and submit to the tax authority is hard to change later. That is why you should call us on the day you receive notice of a tax audit.

Deadlines and the course of a dispute

We represent you during the audit, on appeal (a 30 day deadline from delivery of the decision under § 72 of Act No. 563/2009 Coll., the Tax Code) and in administrative-court proceedings under the Administrative Court Procedure Code (Act No. 162/2015 Coll.). We run the entire case; you focus on your business.