The Czech Financial Administration has published Guidance GFR D-32 (Czech language) on advance pricing agreements (APAs). Some of the main points of the Guidance include:
- An APA application must be submitted by the taxpayer to which the APA will apply or by the non-resident taxpayer whose Czech permanent establishment is affected by the APA;
- The application, including attachments, must be submitted in the Czech language;
- An application may be made for an APA for the tax period in which it i…