CYIL vol. 13 (2022)

MARCELA HRADECKÁ CYIL 13 ȍ2022Ȏ tax. The concept is called BEFIT 29 , and by 2023 the tax base calculation and its subsequent redistribution between the individual Member States should be set up. The European Union is also putting forward other proposals for large multinational corporations and groupings. For example, publishing an effective tax rate, tightening the rules for corporations showing no or little activity, or incentivising business corporations to invest through their equity, i.e., through profits generated rather than foreign capital. Related reporting Intrastat 30 is a statistical system which processes data on the movement of goods, i.e., on intra-Community transactions within the framework of the European Union. The system records volumes of international trade within the European Union, i.e., the movement of goods from the Czech Republic to other EU countries, as well as transactions related to the acquisition of goods from or delivery to another Member State. Concerning the obligation to report data in the Intrastat system, a special regime applies to the supplies in the transit mode and the supplies where the goods have not crossed the border of the Czech Republic but are intended as a delivery of inventory for air or water transport. Persons 31 registered for tax as value added tax payers or persons identified for value added tax are the persons obliged to report in the Intrastat system. The relevant period and threshold for reporting in the Intrastat system is a calendar year and the reporting starts in the month when the threshold value of exported or imported 32 goods is exceeded, which threshold value is CZK 12,000,000 for exported goods and CZK 12,000,000 for imported goods. Reporting is carried out separately for exports and imports. An important consideration in the case of international trade is the currency in which the supplies of goods are invoiced. Most often this will be in EUR. Reporting is performed in the Czech currency, i.e., in CZK, and the conversion of foreign currency into CZK is carried out at the exchange rate used for the purposes of the value added tax return 33 . The reporting of triangular transactions in the Intrastat system is performed in individual steps, i.e., for individual supplies of goods. A supplier from one Member State shall report the supplied goods in the Intrastat system as sold to a third country as the country of destination. The purchaser separately reports the acquisition of goods in the Intrastat system as imported from the other country. The intermediary is a direct trading partner of both the supplier and the purchaser and does not report the goods in the Intrastat system at all, as the goods could at most transit in the intermediary’s Member State, but for the most part this does not happen at all in practice. 29 BEFIT Business in Europe: Framework for income taxation. Available from: https://www.ey.com/cs_cz/tax/tax alerts/2021/evropska-komise-prichazi-s-novou-strategii-pro-danovou-oblast. 30 INTRASTAT – statistical system. Available from: https://www.czso.cz/csu/czso/intrastat_prirucky 31 Intelligence units. 32 Exported or imported goods are considered in the Intrastat system as deliveries of goods within the European Union. The term export and import for the purposes of the Value Added Tax Act is used in accordance with the crossing of the border of the European Union, i.e., when the goods leave the territory of the European Union. 33 In accordance with the Act no. 235/2004 Coll. on the Value Added Tax, as amended. That is, at the exchange rate of the Czech National Bank on the date of the taxable supply (transaction).

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