As of 1 January 2016 an amendment of the Czech Income Tax Act becomes effective where the list of exceptions from the exemption of dividend pay-out is extended. The dividend paid out to the parent will not be tax exempt from the withholding tax if such dividend may be tax deductible by the subsidiary. This refers to so called hybrid loans, where one country considers this financial instrument as a debt and the other country as an equity. This amendment reacts on the amendment of the EU Parent-Subsidiary Directive which has to be implemented in local laws of EU member countries by 31 December 2015.