Fair tax
A basic tenet of a fair tax system is that income is taxed only
once. Violations of this lead to taxpayer outrage and efforts to
circumvent any double taxation. The government's plan to
tighten thin-capitalization rules for loans from related parties
can be justified if the loans are used to avoid Czech tax through
offshore schemes. Harder to justify, though, is a cap of 6% on
the interest rate from an unrelated party that can be claimed as
a deductible expense. Not only will this disadvantage small
companies with high borrowing costs, as HN noted, but it will
also introduce a new element of double taxation. How else could
the finance ministry expect to raise several billion crowns by
making the change? If the interest cost over the 6% limit is in
effect income to the borrower, the lender should be exempt
from tax on its loan profit, as long as it dutifully pays taxes in
the CR. Otherwise, the tax change will merely shift more
borrowing to murky offshore schemes.
[Czech Republic]
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