In a recently published decision, dated 19 April 2012 (No. 5 Afs 45/2011-94), the Supreme Administrative Court held that unrealized foreign exchange gains do not constitute taxable income for corporate income tax purposes. Background From 2004 to 2006, the taxpayer, a Czech-listed company, obtained long-term loans to finance real estate projects. The taxpayer had unrealized foreign exchange gains in respect of these loans, which, in line with the relevant accounting provisions, were reflected in its profit and loss statement. The taxpayer claimed that unrealized foreign exchange gains could not be deemed "income" for corporate income tax purposes. Accordingly, the taxpayer...