Publication result detail

Taxation of an entity without legal personality: the accounting and tax challenges of the Czech trust fund in continental law

BRYCHTA, K.

Original Title

Taxation of an entity without legal personality: the accounting and tax challenges of the Czech trust fund in continental law

English Title

Taxation of an entity without legal personality: the accounting and tax challenges of the Czech trust fund in continental law

Type

WoS Article

Original Abstract

This article describes and evaluates selected aspects of accounting and tax regime of the Czech trust fund. The Czech legislature has resolved the incompatibility between the private law nature of the trust fund and public law requirements through a series of pragmatic legal fictions, which treat the trust fund as a legal person for accounting and tax purposes. The article identifies the Czech tax model as a viable framework for use within a holding structure, whilst also highlighting the regulatory tension between the desire for discretion and the growing pressure for transparency under AML legislation.

English abstract

This article describes and evaluates selected aspects of accounting and tax regime of the Czech trust fund. The Czech legislature has resolved the incompatibility between the private law nature of the trust fund and public law requirements through a series of pragmatic legal fictions, which treat the trust fund as a legal person for accounting and tax purposes. The article identifies the Czech tax model as a viable framework for use within a holding structure, whilst also highlighting the regulatory tension between the desire for discretion and the growing pressure for transparency under AML legislation.

Keywords

Czech Republic, tax neutrality, trust, accounting, taxation.

Key words in English

Czech Republic, tax neutrality, trust, accounting, taxation.

Authors

BRYCHTA, K.

Released

27.07.2025

Publisher

OXFORD UNIV PRESS

Location

OXFORD

ISBN

1752-2110

Periodical

Trusts & Trustees

Volume

31

Number

8

State

United Kingdom of Great Britain and Northern Ireland

Pages from

1

Pages to

6

Pages count

6

URL

https://academic.oup.com/tandt/advance-article/doi/10.1093/tandt/ttaf054/8213726?utm_source=authortollfreelink&utm_campaign=tandt&utm_medium=email&guestAccessKey=75337996-cb64-4a73-81c3-8574eb73e9ee

BibTex

@article{BUT198458,
  author="Karel {Brychta}",
  title="Taxation of an entity without legal personality: the accounting and tax challenges of the Czech trust fund in continental law",
  journal="Trusts & Trustees",
  year="2025",
  volume="31",
  number="8",
  pages="1--6",
  doi="10.1093/tandt/ttaf054",
  issn="1363-1780",
  url="https://academic.oup.com/tandt/advance-article/doi/10.1093/tandt/ttaf054/8213726?utm_source=authortollfreelink&utm_campaign=tandt&utm_medium=email&guestAccessKey=75337996-cb64-4a73-81c3-8574eb73e9ee"
}