IDEAS home Printed from
   My bibliography  Save this article

Complicated Transfer of Tax Losses between Entities in the European Union
[Komplikovaný přenos daňové ztráty mezi subjekty v zemích Evropské unie]


  • Jana Skálová


The article deals with the possibility of taxing the company plans to expand abroad through cross-border mergers. They discussed two alternatives fiscal relations - establishment of a subsidiary company for the use of losses incurred by subsidiary companies to reduce the tax base of the parent company. The second alternative examines the application of the losses incurred during the existence of branches abroad. Income tax advantages that may be gained in cross-border merger were implemented by virtue of Directive 90/434/EEC. The Income Tax Act allows Czech successor companies to take over tax losses that were incurred by foreign merging companies and that have not been used yet. At this point, tax advantages could be at least described as problematic or even unattainable.

Suggested Citation

  • Jana Skálová, 2010. "Complicated Transfer of Tax Losses between Entities in the European Union [Komplikovaný přenos daňové ztráty mezi subjekty v zemích Evropské unie]," Český finanční a účetní časopis, Prague University of Economics and Business, vol. 2010(4), pages 7-18.
  • Handle: RePEc:prg:jnlcfu:v:2010:y:2010:i:4:id:82:p:7-18
    DOI: 10.18267/j.cfuc.82

    Download full text from publisher

    File URL:
    Download Restriction: free of charge

    File URL:
    Download Restriction: free of charge

    File URL:
    LibKey link: if access is restricted and if your library uses this service, LibKey will redirect you to where you can use your library subscription to access this item

    As the access to this document is restricted, you may want to search for a different version of it.

    More about this item


    Cross-border merger; Tax loss; Subsidiary; Branch; Přeshraniční fúze; Daňová ztráta; Dceřiná společnost; Organizační složka;
    All these keywords.

    JEL classification:

    • G34 - Financial Economics - - Corporate Finance and Governance - - - Mergers; Acquisitions; Restructuring; Corporate Governance
    • K34 - Law and Economics - - Other Substantive Areas of Law - - - Tax Law


    Access and download statistics


    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:prg:jnlcfu:v:2010:y:2010:i:4:id:82:p:7-18. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    We have no bibliographic references for this item. You can help adding them by using this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Stanislav Vojir (email available below). General contact details of provider: .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.