Czech Republic Tax Optimization

[daniels27]

@JohnLocke can you chěck this please?

There are two limits. 250 conversations and 250 messages. You need to click on a message to see the message count. Also, please note that the count is updated like once per 6 hours only.

 

[Marzio]

Willing to, but would prefer not to move.

How far are your from the Polish border?

 

[Mieses]

There are two limits. 250 conversations and 250 messages. You need to click on a message to see the message count. Also, please note that the count is updated like once per 6 hours only.

Yes, but how could he delete his messages if @void reached the message limit rather than conversation limit? It seems an unsolved issue.

How far are your from the Polish border?

About an hour drive, why?

 

[Marzio]

About an hour drive, why?

Because if your business does not exceed revenue of 2 million EUR you could slash CIT from 20% to 9% by forming a Polish branch of your Czech company and moving some key operations to Poland.

In basic terms you'll need to send all the invoices from your Polish branch.

It's up to you how often to commute to Poland to demonstrate that work is attributable to the Polish branch.

https://www2.deloitte.com/content/dam/Deloitte/global/Documents/Tax/dttl-tax-polandhighlights-2024.pdf

 

[Mieses]

Because if your business does not exceed revenue of 2 million EUR you could slash CIT from 20% to 9% by forming a Polish branch of your Czech company and moving some key operations to Poland.

In basic terms you'll need to send all the invoices from your Polish branch.

It's up to you how often to commute to Poland to demonstrate that work is attributable to the Polish branch.

https://www2.deloitte.com/content/dam/Deloitte/global/Documents/Tax/dttl-tax-polandhighlights-2024.pdf

Thank you! This tip is very interesting and it would avoid CFC since it's just a branch (I guess) and PE would not be an issue as long as I just did the work related to it from Poland.

Do you know about how the revenue from the branch is taxed in CZ or where can I find info about that? I guess that CZ would not want to double tax that income, in that case it would just be 9% in Poland and 15% Czech dividend when distributing to me.

 

[Marzio]

Do you know about how the revenue from the branch is taxed in CZ or where can I find info about that?

This is coming from PL-CZ double tax treaty.

In that case it would just be 9% in Poland and 15% Czech dividend when distributing to me.

Exactly.

Not a bad optimization for an hour drive 2-3 times a week, right?

You owe me a beer with Silvia Saint.