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Czech Republic vs RR Donnelley: JUDGMENT

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Czech Republic vs RR Donnelley: JUDGMENT

Case Information

  • Court: Supreme Administrative Court (SAC) of the Czech Republic
  • Case No.: 7 Afs 31/2024 – 27
  • Applicant: RR Donnelley Czech s.r.o.
  • Defendant: Odvolací finanční ředitelství (Czech Tax Appeals Directorate)
  • Judgment Date: 28 February 2025

The case Czech Republic vs. RR Donnelley Czech s.r.o. revolved around a transfer pricing dispute concerning the application of Section 23(7) of the Czech Income Tax Act (ITA). The core issue was whether RR Donnelley Czech s.r.o. had correctly applied the arm’s length principle in a transaction involving the purchase of hard disk drives (HDDs) on behalf of Banta Ireland, a related entity.

The Specialised Tax Office initially assessed RR Donnelley Czech for an additional corporate income tax liability of CZK 61,650, along with a 20% penalty of CZK 12,312, arguing that the transaction had not been conducted at arm’s length. The company appealed to the Regional Court in Brno, which annulled the tax authority’s decision, citing insufficient justification for the reference price used by the tax administration.

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Categories: Czechia
Tags: ALP, Arms Length Principle, Benchmarking, Comparability Analysis, Cost Plus Method, TNMM, TP Methods, Transactional Net Margin Method, Transfer Pricing
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5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected		 End of module progress assessment

5000-word assignment if PG-Cert option elected