The Future of Corporate Taxation

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1 The Future of Corporate Taxation Digital Business - Shared Economy - Crypto Currencies - BEPS 5 th April 2018 Gabriela Hoppe, Tax Partner Grant Thornton Tax&Accounting s.r.o.

Grant Thornton International Grant Thornton is one of the world's leading organizations of independently owned and managed audit, tax and corporate consulting firms.

2 Grant Thornton International Grant Thornton is one of the world's leading organizations of independently owned and managed audit, tax and corporate consulting firms. Grant Thornton helps entrepreneurs unlock their growth potential through a wide range of client-tailored services. Our teams supervised by partners, who are open to new insights, use logic, experience and even sixth sense to find a solution to very complex issues of our clients. Our clients include private and public companies as well as clients from the government sector. A team of over professionals in more than 130 countries of the world wants the clients, colleagues and the society we live in, to experience the results of our innovative approach Grant Thornton International Ltd. All rights reserved. Grant Thornton refers to the brand under which the Grant Thornton member firms provide assurance, tax and advisory services to their clients and/or refers to one or more member firms, as the context requires.grant Thornton International Ltd (GTIL) and the member firms are not a worldwide partnership. GTIL and each member firm is a separate legal entity. Services are delivered by the member firms. GTIL does not provide services to clients. GTIL and its member firms are not agents of, and do not obligate, one another and are not liable for one another s acts or omissions. GrantThornton.globall 2

3 Our clients 3

Czech Republic: Prague Brno $ 10.7 m* Annual turnover 8 partners Grant Thornton Tax & Accounting s.r.o. Grant Thornton Audit s.r.o. Grant Thornton Advisory s.

3 offices 109 employees Over the past two decades, Grant Thornton has built a strong position on the Czech market as a provider of audit, tax, accounting

Since the entry of advisory company Facility to the organization in 2011, Grant Thornton has offered full range of services, including the management and

has been delivering services to over 700 clients from private and public sectors, including over half of the Czech TOP 100 companies and many

However the costs of services cannot be left out.

Tax & Accounting s.r.o. *As at 31 December 2016 2018 Grant Thornton International Ltd. All rights reserved.

4 Czech Republic: Prague Brno $ 10.7 m* Annual turnover 8 partners Grant Thornton Tax & Accounting s.r.o. Grant Thornton Audit s.r.o. Grant Thornton Advisory s.r.o. Grant Thornton Valuation a.s. 3 offices 109 employees Over the past two decades, Grant Thornton has built a strong position on the Czech market as a provider of audit, tax, accounting and payroll services. Since the entry of advisory company Facility to the organization in 2011, Grant Thornton has offered full range of services, including the management and transaction consultancy. The annual turnover of exceeds CZK 200 million, with over 100 professionals working in the Prague and Brno offices. has been delivering services to over 700 clients from private and public sectors, including over half of the Czech TOP 100 companies and many multinational companies. Experience has shown that quality services are the deciding factor when choosing a professional consulting company. However the costs of services cannot be left out. Our motto, which we follow in everyday practice is: high-quality professional services at a reasonable price Leoš Horváth Managing Partner, Grant Thornton Tax & Accounting s.r.o. *As at 31 December Grant Thornton International Ltd. All rights reserved. Grant Thornton refers to the brand under which the Grant Thornton member firms provide assurance, tax and advisory services to their clients and/or refers to one or more member firms, as the context requires.grant Thornton International Ltd (GTIL) and the member firms are not a worldwide partnership. GTIL and each member firm is a separate legal entity. Services are delivered by the member firms. GTIL does not provide services to clients. GTIL and its member firms are not agents of, and do not obligate, one another and are not liable for one another s acts or omissions. GrantThornton.globall 4

Our services in the Czech Republic Compilation of tax

planning Preparation of transfer pricing documentation

Payroll accounting Handling of payments, E-payslips HR

Statutory and voluntary audits of financial statements

Financial accounting Methodology and advisory Preparation

US GAAP Reporting under group regulations Management and

Optimization of ICT Forensic services Mergers &

5 Our services in the Czech Republic Compilation of tax returns Tax compliance Identification of tax risks, Tax planning Preparation of transfer pricing documentation Assistance in case of tax inspections, Tax Due Diligence Payroll accounting Handling of payments, E-payslips HR advisory Audit Tax consulting Accounting Payroll agenda Statutory and voluntary audits of financial statements Audit of consolidation packages Financial Due Dilligence Financial accounting Methodology and advisory Preparation of annual financial statements under Czech GAAP, IFRS or US GAAP Reporting under group regulations Management and transaction advisory Valuation Business consulting Optimization of ICT Forensic services Mergers & Acquisitions Business Due Dilligence Funding Valuation of enterprises and real estates

6 Digital business + BEPS Social Media Collaborative Platforms Online content providers Crypto currencies 6

7 Social Media Key aspects and tax issues Where is the value created? Permanent Establishment? 7

8 Collaborative platforms Key aspects and tax issues Trade Licence Personal Income Tax 8

9 Online content providers Key aspects and tax issues MOSS EET 9

10 Cryptocurrencies Key aspects and tax issues Mining x Trading Pools Economic activity? 10

11 Digital tax Interim Solution? selling online advertising space digital intermediary activities sale of data generated from user 3% 11

12 Final solution? CCCTB revenues 7 million users more than 100,000 business contracts 3,000 annual annual annual in a Member State in a Member State between the company and business users 12

13 ? 13

14 Thank you for your attention! 14

Contact details Grant Thornton Audit s.r.o. Grant Thornton Tax & Accounting s.r.o. Jindřišská 16, 110 00 Praha 1 Telefon: +420 296 152 111 Fax: + 420 296 181 484 E-mail: office@cz.gt.

15 Contact details Grant Thornton Audit s.r.o. Grant Thornton Tax & Accounting s.r.o. Jindřišská 16, Praha 1 Telefon: Fax: office@cz.gt.com URL: Gabriela Hoppe Head of Tax T M E gabriela.hoppe@cz.gt.com / Grant Thornton Audit s.r.o., Grant Thornton Tax & Accounting s.r.o. All rights reserved. Grant Thornton Audit s.r.o. and Grant Thornton Tax & Accounting s.r.o. are member firms of Grant Thornton International Ltd (Grant Thornton International). References to "Grant Thornton" are to the brand under which the Grant Thornton member firms operate and refer to one or more member firms, as the context requires. Grant Thornton International and the member firms are not a worldwide partnership. Services are delivered independently by member firms, which are not responsible for the services or activities of one another. Grant Thornton International does not provide services to clients.

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