Building Foundations Mandantenbrief Czech Republic Information on Law, Taxes and Economics in Czech Republic Issue: www.roedl.cz Content: Law > There are other things that impact business besides taxes and commercial law Taxes > Legislation > Taxes Briefly > Judicial decisions Economics > Czech National Accounting Board Interpretation No. I-35 provides a detailed specification of and a procedure for measuring inventory created through own activity Business consulting > The value of a business being valued changes when the time of valuation changes > There are other things that impact business besides taxes and commercial law Nora Haapala, Lucie Kianková, Rödl & Partner Prague Introduction > Is your company a fast-growing start-up, a young successful company, a company well established in the Czech market or a multinational corporation? Irrespective of which of these categories your company fits into, when entering the market, introducing itself to the public and developing its business potential, your firm needs to have a suitable commercial name under which it presents itself to the public. The more successful your company becomes, however, the greater the risk of potential infringements of the rights associated with your commercial name. In order to minimize such risks and avoid potential disputes, companies can make use of the tools available under industrial property rights law. In this article, we will turn our attention to one of these tools, the registration of trademarks. Registered trademark Source: Rödl & Partner Archive The essence of the registration of a trademark at the Industrial Property Office consists of the protection of the designation of a graphical representation, which can consist of words, numbers, letters or a drawing, the objective being to differentiate your company s products or services from those of its competitors. For each applied-for designation, the owner of the designation also selects the category into which such a designation of goods or services can be placed. In addition to the formal requirements for registration, the designation must also qualify for registration from a substantive point of view. This means that only designa- 1
tions that are not identical to already-registered trademarks are eligible for registration. A registered trademark can be registered both for the territory of the Czech Republic and internationally, and such registration is valid for 10 years following the submission of the registration application. What are the benefits of registering a trademark? It should be added that even a designation that is not registered in the trademark register enjoys legal protection if it meets the requirements stipulated in section 10 of Act No. 441/2003 Sb., On Registered Trademarks. Such requirements are, on the one hand, that the designation must have been created and used before an application was filed for the registration of the trademark by another company and, on the other hand, such designation must have been used in accordance with Czech law. If you are considering the registration of a trademark, you should keep in mind the recent decision of the Supreme Court of the Czech Republic dated 26 October 2016, File No. 23 Cdo 3782/2015, in which the Czech Supreme Court examined the relationship between an already-registered trademark and an unregistered designation from the point of view of potential legal protection. In the reviewed case, the Czech Supreme Court affirmed that for the existence of the previous user s right to use an unregistered designation, the extent of use is not the most important factor, what is important is the priority of such use, i.e. whether the rights to such designation arose prior to the submission of the application for the registration of the trademark or not. As the Czech Supreme Court stated: There is no difference between the protection of the rights ensuing from an unregistered designation used by the owner of an automobile repair shop in a small town and the protection of the rights of a manufacturer that uses its unregistered designation for marketing products that are distributed throughout the Czech Republic. What is important is the priority of such use, irrespective of the extent of use. Extent of use is important only when one is dealing with another right, the much stronger right of a previous user, i.e. the right to prevent the registration of a trademark, or the right to have an already-registered trademark declared invalid. In such a case, the not-yet-registered designation must have a much stronger extent of use, i.e. it must be viewed as being characteristic for certain products or services in that the products or services being marketed under such designation have a prominent presence in the market. In practice, however, it can be quite difficult to demonstrate the length and extent of use of a designation. Although the Act on Registered Trademarks provides a certain degree of legal protection to unregistered designations, it cannot be ruled out that the existing, problematic state of affairs where the rights of users of unregistered designations can end up being infringed will not be remedied, even if the above-described requirements are met. This could cause considerable harm to the parties affected by such infringements. Recommendations If you have been building the reputation of your firm on a long-term basis, have been producing products or providing services that are marked with your company s commercial name or other original designation, the registration of a trademark is most certainly advisable. Registration of your trademark also makes sense even in those situations where there is a certain risk that such designation of your products or services could end up being misused by another party. A legal search of industrial rights is just one of the key factors that will help you decide whether to register the relevant trademark or other industrial right (for example, an invention or an industrial prototype). A legal search can also provide you with information on the current status of your commercial name or other designation in the relevant geographic market and can help identify any risks that could have a financial impact on your company. Contact details for further information: Mgr. Nora Haapala Attorney-at-law Senior Associate Phone: +420 236 163 760 E-mail: nora.haapala@roedl.cz Source: Rödl & Partner Archive 2
> Legislation Alexander Novák, Lenka Krupičková Rödl & Partner Prague Information from the General Tax Directorate on the reverse charge mechanism applicable to electronic communication services As of 1 October 2016, the reverse charge mechanism applies to selected telecommunications services. Since there were a number of unclear issues, on 2 February 2017 the General Tax Directorate published an addendum to the information previously provided on the application of this mechanism. In the case of VAT payers that had thus far applied a different approach and did so in good faith, their approach will not be challenged by the tax authority. Differing points of view on this issue had arisen primarily with regard to transactions between providers of telecommunications services and the recipients of the services. It was not always entirely clear whether the recipient had purchased the service in order to resell it. The abovedescribed addendum states that the reverse charge mechanism will only be applied to situations where the recipient is purchasing a specified service in order to resell it, and engages in such reselling of the telecommunications service on a long-term basis, in their own name and on their own account, and for the purpose of achieving a profit. In situations where the recipient is purchasing the telecommunications service for their own use, or in order to provide the use of such service to other end users (employees, subsidiaries in a holding company, tenants, customers or guests), the reverse charge mechanism will not be applied between the operator and the recipient of the service. However, the requirement is that the recipient of the relevant service can only re-bill the service, i.e. the recipient cannot mark up the service with the intent of achieving a profit on it. An intent to achieve a profit is not, however, intended to mean situations where the price is increased merely by the amount of the administrative costs incurred in connection with the re-billing of the service. While the addendum answered a number of key issues, certain areas of the application of the reverse charge mechanism remain unclear. For example, in relation to the method used for the determination of a Cost+ price between related parties. Conditions for prolongation of the time limit for filing a tax return For taxpayers that are not required to have a mandatory audit performed, the end of the time limit for filing an income tax return for 2016 is fast approaching. This year, the last day of the time limit falls on 3 April 2017. Even in the case of taxpayers that are not required to have a mandatory performed, it is possible to have the time limit for filing a tax return prolonged by another three months, i.e. to 3 July 2017. The condition for eligibility for such prolongation is that the relevant taxpayer s tax return must be prepared pursuant to a power of attorney by a tax advisor, and the relevant power of attorney must be delivered to the tax authority no later than 3 April 2017. A number of tax authority employees take the view that for a successful prolongation of the time limit, a hard copy of the original of the power of attorney must be delivered to the relevant local office of the tax authority no later than on the last day of the time limit (i.e. by 3 April 2017). In the view of most tax authority employees, a proper delivery of the power of attorney means that the taxpayer either physically hands over the original of the power of attorney to the mailroom of the tax authority office or sends it by mail sufficiently in advance so that it is delivered by the end of the time limit, or sends an electronic copy (a scan) of the power of attorney via the taxpayer s databox (in cases where instead of being sent by the taxpayer, the power of attorney is sent by the taxpayer s tax advisor via the tax advisors databox, the tax authority additionally requires a so-called authorized conversion of such power of attorney to be performed). The Supreme Administrative Court, however, interpreted the requirement for eligibility to use the submission of a power of attorney to obtain a prolongation of the time limit for filing in a considerably less stringent manner. In a judgment issued on 15 May 2015, the Supreme Administrative Court dispelled the general belief held by tax authority employees that the power of attorney for the tax advisor must be physically delivered to the relevant local office of the tax authority. The Supreme Administrative Court concluded that it does not matter when the power of attorney actually reaches the relevant tax authority office, stating that is suffices if the power of attorney is addressed to (any) office of the tax authority (or even to the Department of Appeals of the Tax Directorate) and is submitted in time to the post office for postal delivery. This means that in order to successfully obtain a prolongation of the time limit for filing a tax return, it is quite sufficient if on the last day of the time limit (i.e. 3 April 2017), the taxpayer delivers the letter containing the power of attorney to the post office for mailing, and the letter may be addressed to any tax authority office. In this regard, it does not matter when the letter containing the power of attorney is actually physically received by the relevant tax authority office. This conclusion was also affirmed by current judgments issued by the Supreme Administrative Court on 10 November 2016 and 22 December 2016, in which the Supreme Administrative Court additionally emphasized that this was not an isolated court decision, that this was in fact a decision supported by arguments and that tax authority employees were obliged to respect the decision and to comply with it during the performance of their work. In other words, the Supreme Administrative Court instructed tax authority employees to change their established practices in relation to the submis- 3
sion of powers of attorney for the purpose of a prolongation of the time limit for filing a tax return, to change such practices so as to bring them into compliance with the cited decisions of the Supreme Administrative Court. Opinion of the General Tax Directorate regarding online payments On 1, the 2 nd phase of the rollout of electronic sales reporting commenced. This phase applies to retail and wholesale sectors. The 2nd phase also applies to most sales occurring via internet-based payment transactions (in e-shops) The General Tax Directorate has now issued an opinion specifying the time when an electronically reportable sale is deemed to have occurred in relation to such sales transactions. When reporting sales electronically, the relevant taxpayer (i.e. the party that received payment for the sale and has a duty to remit VAT on it) has a duty to send, no later than at the time when the electronically reportable sale takes place, a data message to the tax authority containing the relevant information on such sale and to issue a receipt to the customer. When payments are made via a payment terminal in a brick-and-mortar store, or in the case of online payments via a payment gateway, the time of sale is deemed to be the time when the instruction to make the payment is issued. Under a strict interpretation of the Act on Sales Reporting, one could take the view that the time of realization of a reportable sale occurs, in the case of internet-based payments, already when the payment gateway is accessed. However, the General Tax Directorate has now allowed that a taxpayer is entitled to send the information on reportable sales to the tax authority, and issue the relevant receipt to the customer, at the time when the taxpayer actually learns that the relevant payment was debited from the customer s account and sent to the taxpayer reporting the sale. However, in situations where such time is preceded by the shipping of the relevant goods or provision of the relevant service, the taxpayer receiving the payment is obligated to report the sale no later than at the time when the goods are shipped or the service is provided. In the case of online purchases, the mandatory receipt may be delivered to the customer electronically, or it may be enclosed in printed form with the shipped goods. Source: Rödl & Partner Archive This opinion from the General Tax Directorate naturally does not preclude taxpayers from reporting sales earlier, for example at the time an order is received from a customer. In such cases, if the customer subsequently cancels the order, the reported sale can be also cancelled (i.e. reversed). Taxes Briefly International cooperation in the area of taxation The Czech parliament is currently debating an amending bill to the Act on International Cooperation in the Area of Taxation. The amending bill serves to transpose EU Council Directive 2016/881 into Czech law. The regulation applies to companies operating in the Czech Republic that form part of multinational groups with a consolidated turnover of EUR 750 million or more. Such multinational groups will have an obligation to submit mandatory reports featuring a breakdown by individual countries, on their revenues, pre-tax profits, income tax paid and income tax accrued, number of employees, amount of stated capital, accumulated earnings and tangible assets. The transposition of the EU directive is to be completed so that it enters into effect on 5 June 2017. Treaty on elimination of double taxation with Chile A treaty with Chile on the elimination of double taxation and prevention of tax evasion in the area of income taxes and taxes on assets has entered into force. Contact: alexander.novak@roedl.cz martina.sotnikova@roedl.cz > Judicial decisions Jana Vejrová, Rödl & Partner Prague VAT implications of remuneration paid to managing directors At the end of last year, the Supreme Administrative Court issued a judgment in which it had evaluated the VAT implications of remuneration paid for the performance of the post of a managing director. The Czech Act on Value Added Tax excluded the activity performed by managing directors from the category defined as economic activity and instead classified it as an activity that is the same as that performed by employees. 4
The Supreme Administrative Court addressed the matter of a company s claim for a VAT deduction, where the tax authority, as well as the lower-level courts that subsequently adjudicated the matter, disallowed a claim for a VAT deduction in the case of a company whose managing director regularly invoiced such company for his services, and where such invoices included VAT. The Supreme Administrative Court stated that the company had been entitled to claim the tax deduction in view of the direct effect of Council Directive 2006/112/ES on the common system of value added tax (the Directive ). The Directive states that the only activity that is not deemed to be independent economic activity is the activity performed by employed persons and other persons that are bound to the employer by a contract of employment or by other legal ties. By contrast, the Czech Act on Value Added Tax additionally excludes from the category of independent economic activity the activities of those persons whose income is taxed in the same manner as employment income (which also applies to managing directors). The relevant provisions of the Directive have a direct effect with regard to the issue being addressed, meaning that from the point of view of their content, such provisions of the Directive are unconditional and sufficiently clear and precise. Accordingly, the Supreme Administrative Court ruled that in the reviewed case, EU law is to be applied, to the detriment of the national regulation. So the managing director of a company is entitled to treat their activity as economic activity and charge VAT for such activity at the output level. And the company for which the managing director performs such activity is entitled to claim a VAT deduction in respect of such VAT at the input level. Under EU law, the direct effect of a directive can only be applied to the benefit of individuals, not when it is to their detriment. In view of this, the Supreme Administrative Court additionally pointed out that until such time as the Czech Act on Value Added Tax is amended accordingly, tax authorities do not have the right to impose supplementary VAT assessments at the output level on managing directors on the basis of the conclusions set forth in the aforementioned judgment. Contact details for further information: Mgr. Lenka Krupičková, LL.M. Attorney-at-law, Tax advisor Senior Associate Phone: +420 233 111 261 E-mail: lenka.krupickova@roedl.cz > Czech National Accounting Board Interpretation No. I-35 provides a detailed specification of and a procedure for measuring inventory created through own activity Jaroslav Dubský, Jana Kocurková Rödl & Partner Prague Introduction During the preparation of their annual financial statements, many companies had to tackle the issue of how to properly measure inventory created through own activity (own products and work) in compliance with the law and the implementing decree that entered into force on 1 January 2016. Since this accounting issue is quite topical and important, in this article we will revisit it, after having addressed it in other Mandantenbrief articles and during our accounting seminars. Both the Act on Accounting and Decree No. 500/2002 Sb., which entered into effect on 1 January 2016, lacked a detailed set of instructions on how to proceed when measuring inventory (i.e. valuing inventory) created through own activity. For that reason, in October 2016, the National Accounting Board issued Interpretation I-35 which aims to stipulate a uniform procedure to be followed in this area of financial accounting. The Interpretation addresses the following fundamental issues: Ing. Alexander Novák, LL.M. Tax advisor Senior Associate Phone: +420 233 111 261 E-mail: alexander.novak@roedl.cz > how to delineate direct and indirect costs relating to production, and > whether indirect costs are required to be a component of own costs > procedure for measuring inventory by means of predetermined costs (planned costs) > anticipated impairment of inventory and assessment of loss-making orders 5
Own costs for inventory created through own activity are deemed to consist of the direct costs incurred for production and any indirect costs relating to production. The following table provides a brief and basic characterization, as well as examples, of own costs as set forth in the Interpretation: Own production costs Direct Indirect Indirect variable, indirect fixed Examples of costs included in costing calculations > Consumption of material in production; > Consumption of labor (wages) used for production of cost unit; > Sub-supplies of services for processing of the relevant cost unit > Consumption of water, electricity and gas in production; > Activity-based depreciation (i.e. depreciation based on units produced) or time-based depreciation of production equipment; > Depreciation of buildings used in production; > Leasing cost of production premises; > Costs of technical preparation of production; > Maintenance; > Quality-related costs General characteristics > Costs reasonably and purposefully expended for production of cost unit; > these can be allocated to a cost unit directly; > these are predominantly variable costs tied to the volume of production > Costs reasonably and purposefully expended for production can be assigned to a cost unit only through allocation, using an appropriate allocation base; > These can be fixed costs or variable costs tied to the volume of production Own costs expended for inventory produced through own activity are measured at the actual amount of such costs or on the basis of production costing. As follows from the above overview, own costs include, in addition to direct costs, also a proportional part of the indirect variable and fixed costs assignable to the period in which the relevant products were produced. The aforementioned decree also expressly states that selling costs should not be included in the acquisition cost of inventory produced through own activity. A key specification is the specification that direct and indirect costs are those costs that were reasonably and purposefully incurred for production. According to this interpretation, purposefully incurred secondary costs are all those costs that were incurred for bringing inventories to their present location and condition. Reasonably incurred costs are understood to be those costs that were expended in compliance with the principles of economy and efficiency, costs that needed to be expended for bringing inventories to their present location and condition. While in the case of direct costs, the above specification is easy to understand and does not create any major difficulties in practice, the situation becomes more difficult in the case of indirect costs. Those indirect costs that do not meet the above definitions, i.e. indirect costs that are not usually considered to be costs that were reasonably or purposefully incurred for production, are not supposed to be included in the measurement of inventory produced through own activity and are instead charged directly to current period costs. However, this cannot be stated in relation to all situations generally, one needs to always take into consideration the specific issues pertaining to, and the length of, the relevant production process. Examples of such costs are summarized below: Examples of costs typically not considered to be costs purposefully incurred for production > Administrative costs > Financial expenses > Selling costs > Costs for storage or movement of inventory within warehouses (unless these costs are part of the production process) Examples of costs typically not considered to be costs reasonably incurred for production > Abnormal waste > Avoidable damage > Labor that was not expended in a reasonable manner > Costs associated with unused capacity Another key decision that needs to be made during the process of measurement of inventory produced through own activity is the decision on what is the appropriate allocation base to use in relation to the degree of use of production capacity in costing calculations. This applies particularly to situations where during the relevant period, the actual use of production capacity was not in line with the customary or anticipated use of production capacity. Customary use of production capacity is understood to mean the anticipated production volume (the production volume that will be achieved or is achieved on average Zdroj: archiv Rödl & Partner 6
over the course of several periods or seasons under normal circumstances), while taking into account the capacity that will not be used due to scheduled maintenance of production equipment. The table below describes the use of the allocation base in relation to various degrees of capacity use as well as the procedure for including own costs for products in the costing calculation Degree of capacity use Abnormally low production volume or production equipment is not used at all Actual production volume approaches production capacity Abnormally high degree of use of production capacity Use of allocation base in relation to capacity use > Allocation base for assignment of indirect fixed costs to cost unit = customary degree of capacity use (not the actual degree of use of production equipment) > Non-assigned indirect fixed costs are treated as current period costs and consequently they are not included in the measurement (i.e. valuation) of own production in the relevant period > Allocation base = actual volume of production > The amount of indirect fixed costs assigned to a cost unit will be reduced so that inventory is not measured (i.e. so that it is not valued) higher than the actual costs incurred. > Variable indirect costs are assigned to a cost unit in relation to the actual degree of use of production equipment. If a reporting entity measures inventory produced through own activity on the basis of costing that contains predetermined costs (planned costs), then no later than on the balance sheet date, such reporting entity must compare the own costs so determined with the actual own costs incurred for the inventory produced through own activity. In the event that on the balance sheet date, a material difference is ascertained between the two measurements of inventory (i.e. between the measurement of inventory using the predetermined costs and the measurement of inventory using the actually-incurred costs), then on the balance sheet date the reporting unit needs to adjust the measurement of inventory (i.e. the value at which inventory is reported in the balance sheet) to the level of the actually-incurred own costs. This must be done because where there are several permitted accounting methods that reporting units are allowed to use, reporting units have a duty to always use the method that best reflects the true state of affairs (see 7 (2) of the Act on Accounting). This procedure is aimed at ensuring that a predetermined, i.e. estimated, level of own costs, will be subsequently replaced by a more precise measurement (i.e. valuation) through the use of the costs actually incurred. Such an adjustment represents a changed estimate, not a change of method. A change of method is accounted for only in those situations where a reporting entity changes the procedure used for measurement of inventory produced through own activity (for example, the reporting entity starts including indirect costs in the own costs it reports, or if the reporting entity expands production overhead or, on the other hand, ceases to include administrative overhead in its costing calculations). Such situations would constitute a change of accounting method, and this would have to be accounted for in compliance with Interpretation I-29. By means of an internal guideline, a reporting unit is supposed to lay down a mathematical formula to be used for differentiating costs into direct costs, indirect variable costs, and indirect fixed costs. The internal guideline should also lay down the allocation base to be used. It should also lay down the rules specifying what is considered material with regard to the measurement of inventory in situations where there is the above-described difference between actually-incurred costs and planned costs. On the balance sheet date, it is also necessary to determine, on the basis of an inspection of inventory, whether any impairment occurred to the value of the produced inventory. In cases where inventory produced through own activity, including all anticipated costs for the full future completion of such inventory, had been measured at a value that is higher than the anticipated selling price (less any anticipated selling expenses), such fact needs to be reflected by an adjustment to the carrying value of inventory. If it is certain (for example, in situations where the company has already concluded contracts pursuant to which the future production or future work will be sold at a loss) that a loss will be incurred in the future, the reporting unit must create an allowance for the future losses on the relevant project. In the above-described Interpretation, the National Accounting Board attempted in an admirable manner to provide more detail on the procedures to be used for the measurement of inventory produced through own activity. In particular, the National Accounting Board provided a more detailed specification of the own costs reasonably and purposefully incurred in production and a specification of how such costs should be captured in costing, financial accounting and in the financial statements, which must provide a fair and honest representation of reality The National Accounting Board partly drew inspiration from the international accounting standard IAS 2, thereby hoping to make things somewhat easier for those reporting entities that, in addition to the preparation of their own financial statements, also prepare IAS/IFRS-compliant financial statements for consolidation purposes at the level of their parent company. The National Accounting Board also helped fill in certain gaps in the definitions set forth in the Act on Accounting and the implementing decree to such 7
Source: Rödl & Partner Archive act. Nevertheless, there still remain a number of topics and areas that could use a more precise and more detailed specification in accounting legislation, or at least some guiding interpretations from accounting authorities that could be used in practice by reporting entities. Contact details for further information: > The value of a business being valued changes when the time of valuation changes Jaroslav Chovanec, Rödl & Partner Brno Introduction Ing. Jaroslav Dubský, FCCA Auditor Partner Phone: +420 236 163 309 E-mail: jaroslav.dubsky@roedl.cz Even if the business activity of a business remains the same and the outlook remains stable, the value of the business can change as a result of changes in its environment. The value of a business cannot be viewed as constant simply because the operating results of the business are not changing. 8
During the regular conduct of their business, enterprises are frequently required, in compliance with duties imposed by legislation, to have an expert opinion prepared on the market value of all or part of the relevant business. This duty to have an expert opinion prepared usually arises as at a certain date. Sometimes we encounter situations where a client asks if it would be possible to simply re-use an already-prepared, previous expert opinion with a different valuation date. This suggestion is frequently supported by the argument on the client s part that nothing substantial has changed in the client s business activities and that consequently it should be possible to simply use the value previously determined as at another date in the past. An example of this would be a situation where a client that leases out a real estate portfolio on the basis of long-term leases which have an inflation clause and where such client receives rental payments without any problems. In this situation it really would apply that nothing material has changed. However, a valuation of a business does not merely consist of an isolated assessment of its specific situation, such valuation also encompasses an assessment of the overall background situation in which the business operates. The valuation of a business involves comparing the business to other, alternative investment opportunities. And while it may well be the case that the income associated with the business being valued does not change over time, this will probably not apply to the aforementioned alternatives. However, it is in the context of such changing investment opportunities that the market value of the business being valued will have to be determined. If there are changes occurring in the business environment, the value of the business being valued will also change, despite the fact that the income and risks associated with the business have not changed. A higher number of attractive opportunities in other areas can have the effect of reducing the attractiveness of a business that has remained unchanged internally. Although the Source: Rödl & Partner Archive 9
business may have a steady income that has been contractually secured on a long-term basis, higher uncertainty as a result of, for example, political or military conflicts will have an effect on the value of the relevant business. While in general one cannot reduce the issues involved to such a simplified statement, it can be stated that one of the key indicators of the degree of change in the environment in which the business being valued operates consists of interest rates. Changes in interest rates, whether in consequence of greater or fewer alternative opportunities or in consequence of geopolitical changes, directly affect the value of the business being valued, even though (as yet) the business itself has remained unchanged. Changes in interest rates are a direct reflection of alternative opportunities. Accordingly, in order to determine the value of a business at a different point in time, it is necessary to have a new expert opinion prepared. The new expert opinion will determine a value not only on the basis of the internal situation of the business being valued, but also on the basis of an analysis of the current environment. The fact that nothing has changed internally at the business being valued is not a sufficient reason for concluding that the value of the business has also remained unchanged. Contact details for further information: Ing. Jaroslav Chovanec, Ph.D. Expert Phone: +420 530 300 500 E-Mail: jaroslav.chovanec@roedl.cz Building Foundations Our experise and experience lay the foundations for our advisory services. On those foundations we build, together with our clients. Rödl & Partner Our unique human towers needs a strong and solid foundation Castellers de Barcelona Each and every person counts to the Castellers and to us. Human towers symbolise in a unique way the Rödl & Partner corporate culture. They personify our philosophy of solidarity, balance, courage and team spirit. They stand for the growth that is based on own resources, the growth which has made Rödl & Partner the company we are today. Força, Equilibri, Valor i Seny (strength, equilibrium, valour and common sense) is the Catalan motto of all Castellers, describing their fundamental values very accurately. It is to our liking and also reflects our mentality. Therefore Rödl & Partner embarked on a collaborative journey with the representatives of this long-standing tradition of human towers Castellers de Barcelona in May 2011. The association from Barcelona stands, among many other things, for this intangible cultural heritage. Imprint Mandantenbrief Czech Republic, MK ČR E 16542 Published by: Editorial Board: Rödl & Partner Consulting, s.r.o. Platnéřská 2, 110 00 Prague 1 Phone: + 420 236 163 111 www.roedl.cz Ing. Jana Švédová jana.svedova@roedl.cz Layout/Typeset by: Rödl & Partner publikace@roedl.cz This newsletter is an information booklet intended for general informative purposes. The information is not advice, should not be treated as such, and you should not rely on the information in the newsletter as an alternative to legal, taxation, financial, accountancy or corporate advice. Although we prepare the information for the newsletter with utmost care, we do not represent, warrant, undertake or guarantee that the information in the newsletter is correct, accurate, complete, non-misleading or up-to-date. Since the information presented here do not discuss specific cases of particular individuals or corporations, you should always verify the information applicable to your circumstances by consulting an appropriately qualified professional. We disclaim liability for any decisions made by readers based on information in our newsletters. Our advisors will gladly assist you with any questions on topics presented here or with any other matters. The entire contents of our newsletters as published on the internet, including the information presented here, represent the intellectual property of Rödl & Partner and are protected by copyright laws. Users may download, print or copy the contents of the newsletters for their own needs only. Any modification, reproduction, distribution or publication of the contents of the newsletter, in whole or in part, whether online or offline, is subject to a prior written consent of Rödl & Partner.