Global

Details

  • Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 5/21/2014

Czech Republic - Reporting requirements for cash pooling transactions 

May 21: Certain cash pooling transactions are subject to a reporting requirement of the Czech National Bank (CNB). If these transactions are not reported to the CNB, relatively severe penalties may be imposed.

Decree No. 34/2003 Coll., on the fulfilment of the reporting requirement under the foreign exchange law, explicitly lists cash pooling transactions as transactions exempt from the CNB reporting requirements. However, that decree was superceded by Decree No. 235/2013 Coll., in August 2013 and the newer decree does not specify any such exemption. The more recent decree only determines the annual limits pertaining to funds received from or provided to foreign countries on the basis of which the person concerned has the duty to prepare a report of transactions made and then to submit it to the CNB.


Even though the text of the new decree does not mention cash pooling, the position of officials with the CNB is that similar transactions within the limits under the decree are to be viewed as loans. If the total annual volume of funds provided or received by a Czech entity to or from a foreign country is at least CZK 100 million, the entity has a duty to prepare a monthly report on financial loans and to submit it to the CNB.


If an entity does not comply with this reporting requirement, the CNB may impose a penalty of up to CZK 1 million.


For more information, contact a KPMG tax professional in the Czech Republic:


Martin Hrdlík

+420 222 123 392


Linda Cechová

+420 222 123 889

 




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