By: Martin Hahn
July 28, 2025 4 min read
On 23 July 2025, the Senate of the Czech Republic discussed and approved an amendment to the Act on Top-up Taxes (Senate Document No. 160).
We do not expect the President to veto the bill. After almost a year (the draft law was sent to MPs on 29 August 2024), we can therefore expect the amendment to come into force, which fundamentally changes the conditions of the top-up taxes for the year 2024 already.
The main motive and certainty for taxpayers will be the postponement of the deadline for filing information reports (within 15 months, or 18 months for the first period) and the postponement of the deadline for filing tax returns (within 22 months). Therefore, if the first reporting period is the calendar year 2024, the information return will need to be filed by 30 June 2026 and the tax return by 31 October 2026. So, there should be enough time for everything. This gives all companies concerned more time to prepare.
As we have informed you earlier (here), the Ministry of Finance of the Czech Republic has published a draft Decree on form submissions for the top-up taxes. During the comment procedure, the Chamber of Tax Advisors of the Czech Republic sent comments that it would be appropriate to create a form within the EPO application for the information overview and the tax return for the top-up taxes. So far, only a mandatory electronic xml format is envisaged, where each tax entity would have to ensure compliance with the xml format itself (i.e. essentially as currently for the CbCR or DAC7 notifications). Creating an EPO form would reduce the potential for filing errors.
Referring to earlier information (here) regarding the attitude towards the US not directly implementing the Pillar 2 rules, a discussion has also been sparked within the EU. There are attempts to consider the current system in the US analogous to the Pillar 2 rules. Thus, the debate is at the level of how and whether to apply the assigned top-up tax rules (IIR and UTPR), particularly in relation to groups with US member entities, while the implementation of national top-up taxes is not questioned.
If you are subject to or interested in the regulation of top-up taxes, please, do not hesitate to contact our specialists who have the most up-to-date knowledge of the subject.
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