Although it has been more than half a year since the draft amendment on the top-up tax was introduced in the Chamber of Deputies, it has not yet been approved.

This amendment is very crucial and brings the original Czech Act No. 426/2023 Coll., on the top-up taxes for large multinational groups and large domestic groups, into greater compliance with the OECD and EU interpretations of the Directive in this area.

The amendment has now been considered by the Budget Committee, which has suspended consideration of the amendment until 19 March 2025 and set a deadline of 12 March 2025 for the submission of written amendments.

The transitional provisions have not been changed and it is still the case that the amendment should apply to tax obligations for top-up taxes for the tax period commencing on 31 December 2023, i.e. from the beginning of the entry into force of Act No.426/2023 Coll.

We will keep you informed about any further development. Similarly, we continuously monitor the interpretations of the Finance Ministry of the Czech Republic, or possibly the General Financial Directorate in this area (e.g. new forms, methodological guidelines, etc.).

If you are subject to or interested in the regulation of top-up taxes, please do not hesitate to contact us. We are ready to discuss the possible impact on your group with you.