Abstrakt
The chapter describes the introduction of the so called mandatory disclosure rules (MDR, the obligation to collect and disclose information on potentially aggressive or abusive cross-border tax planning arrangements, including the subsequent automatic exchange of information on them) in the Czech Republic as a result of the implementation of the amending directive (DAC6) to the Council Directive on administrative cooperation in the field of taxation. The chapter contains a detailed description of the newly introduced rules.
The authors identified several problems with the regime and express theirs doubts about the practical effect of the new rules and the value added of having such rules in place.