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| September 10, 2024
In May 2024, we informed you in our article that the Ministry of Finance of the Czech Republic has submitted an amendment to Act No. 426/2023 Coll., on top-up taxes for large multinational groups and large domestic groups for the comment proceeding.
Currently, this amendment has been approved (with several modifications) by the Government of the Czech Republic and sent to the Chamber of Deputies of the Parliament of the Czech Republic as Parliamentary Document No. 783/0. The first reading of this amendment is scheduled to take place during the 112th session starting on 10 September 2024.
The main reason for the amendment is still to increase consistency of the wording of the Czech legislation with international interpretations of the OECD as well as the EU Directive, in particular the possibility to consider the local Czech top-up tax to be qualified.
According to the transitional provisions, the amendment will probably already apply to tax obligations for compensatory taxes for the tax period starting from 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.
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.