Further developments in the area of top-up taxes

International Taxes Advisory

By: Martin Hahn

Further to our earlier information (here), we would like to give you a brief update on the situation.

Amendment of the Czech law on top-up taxes is a little closer again

In the Czech Republic, the amendment to the Act on the Top-up Taxes (Parliamentary Document No. 783) is still in the Chamber of Deputies, but it has already been advanced to the third reading. We are therefore one step closer to its approval, which would primarily mean a postponement of the deadlines for submitting the Czech information report and the Czech top-up tax return for the reporting period 2024 to 2026.

DAC 9 approved by the EU Council

On 14 April 2025, the EU Council approved the DAC 9 proposal. Therefore, for 2024, there will be the option of submitting one information sheet for the entire group in the EU.

OECD Consolidated Commentary

On 9 May 2025, a new OECD consolidated commentary on the issue of top-up taxes was published. This consolidated commentary already includes all OECD guidance (“Administrative Guidance”) issued up to March 2025.

If you are subject to the regulation of top-up taxes or are interested in this area, please, do not hesitate to contact our specialists who have up-to-date knowledge of the issue.