Although by the end of 2023 all Member States were already obliged to implement Council Directive (EU) 2022/2523 on ensuring a global minimum level of taxation of multinational enterprise groups and large domestic groups in the Union in their local legislation, in some cases this has not yet been done.

These “transgressors” are Spain, Portugal, Cyprus and Poland.

Although amendments or new draft laws are already on the table in some countries, they have not yet been officially approved and implemented.

The European Commission is not pleased about this and has submitted this to the EU Court of Justice – see HERE for more details.

If you will be subject to the regulation of top-up taxes (in the Czech Republic or abroad) or if you are interested in this area, please, do not hesitate to contact us.