MEASURES TO RESTRICT ABUSE OF THE PARENT-SUBSIDIARY DIRECTIVE
In January 2015, the EU Council amended Directive 2011/96/EU on the common system of taxation applicable to parent companies and subsidiaries of different Member States. The objective of the Directive is to exempt dividends and other profit distributions paid by subsidiary companies to their parent companies from withholding taxes and to eliminate the double taxation of such income for the parent company. The objective of January’s amendment is to prevent companies from taking advantage of unintended benefits from the Directive and requires Member States to deny tax benefits to companies which show transactions which merely provide a tax advantage but which otherwise have no due business grounds.
The Czech Republic is required to respond by 31 December 2015 and put in place legislation that will ensure that Czech law is harmonized with the Directive. Thus, taxpayers will need to be able to prove to the tax authorities that the transactions shown in their tax records did in fact take place on sound business grounds.
Other articles
KŠB Assisted with the Refinancing of the BigBoard Group, a leading player in the premium outdoor advertising market
Our team provided legal advice to BigBoard Praha, a leading player in the premium outdoor advertising market in the Czech Republic, in connection with its refinancing. Founded in 1993, the BigBoard Group is the largest provider of premium outdoor advertising in the Czech Republic, with an approximately 70% market share and annual turnover of around CZK 2 billion. Its advertising media cover key locations across the country, including the Prague metro and major transport hubs.
KŠB Assisted Sandberg Capital with a Majority Investment in HotelTime Solutions
The KŠB team provided legal advice to the investment group Sandberg Capital on the completion of a majority investment in HotelTime Solutions, one of the leading providers of cloud-based software for hotel operations management.
KŠB assisted Seyfor with the extension of its financing provided by Raiffeisenbank, Tatra banka and, newly, Slovenská sporiteľňa.
The KŠB team provided legal advice to its long-standing client Seyfor in connection with the continuation and expansion of its syndicated financing. The existing lending banks, Raiffeisenbank Czech Republic and Tatra banka, decided to continue supporting Seyfor’s growth, with Slovenská sporiteľňa joining the financing as a new lender.
