Publication result detail

Transfer Pricing and Intra-group Losses. The Czech Republic v. Stora Enso Wood Products Ždírec s.r.o.

SOLILOVA, V.; BRYCHTA, K.

Original Title

Transfer Pricing and Intra-group Losses. The Czech Republic v. Stora Enso Wood Products Ždírec s.r.o.

English Title

Transfer Pricing and Intra-group Losses. The Czech Republic v. Stora Enso Wood Products Ždírec s.r.o.

Type

Chapter in a book

Original Abstract

The analysed case demonstrates an attempt by tax authorities to extend the applicability of the ‘order from the parent company’ beyond contractual obligations into the realm of standard business decision-making processes, such as the cessation of loss-generating activities, which carries accounting and tax implications. In this case, the SAC remains consistent with its prior rulings, emphasizing the importance of carefully and objectively weighing all circumstances of each specific case. However, the interpretation of the ‘parent order’ is still being developed by the SAC.

English abstract

The analysed case demonstrates an attempt by tax authorities to extend the applicability of the ‘order from the parent company’ beyond contractual obligations into the realm of standard business decision-making processes, such as the cessation of loss-generating activities, which carries accounting and tax implications. In this case, the SAC remains consistent with its prior rulings, emphasizing the importance of carefully and objectively weighing all circumstances of each specific case. However, the interpretation of the ‘parent order’ is still being developed by the SAC.

Keywords

Case-law; Czech Republic; Tax Loss; Transfer Pricing

Key words in English

Case-law; Czech Republic; Tax Loss; Transfer Pricing

Authors

SOLILOVA, V.; BRYCHTA, K.

Released

24.09.2025

Publisher

Wolters Kluwer

Location

Alphen aan den Rijn

ISBN

9789403513294

Book

Transfer Pricing Case Law Around the World 2025

Pages from

183

Pages to

209

Pages count

26

BibTex

@inbook{BUT198975,
  author="{} and Karel {Brychta}",
  title="Transfer Pricing and Intra-group Losses. The Czech Republic v. Stora Enso Wood Products Ždírec s.r.o.",
  booktitle="Transfer Pricing Case Law Around the World 2025",
  year="2025",
  publisher="Wolters Kluwer",
  address="Alphen aan den Rijn",
  edition="1st",
  pages="183--209",
  isbn="9789403513294"
}