By: Petr Němec, Martin Hahn
April 8, 2025 4 min read
We would like to inform you briefly about the current development of legislation in the area of top-up taxes in the Czech Republic.
As we have informed you before (here), the Chamber of Deputies has received the parliamentary print number 783, which, in addition to the amendment to the Accounting Act and the Auditors Act, also contains an amendment to Act No. 426/2023 Coll., on the top-up taxes for large multinational groups and large domestic groups.
During the legislative process, amendments were proposed to the amendment, which are partly of a technical nature, but also implement further OECD interpretations, this time from January 2025.
The aim is to have the Czech law on top-up taxes in line with OECD rules so that both the Czech top-up tax and safe harbours are considered qualified.
Within the EU, DAC 9 has been introduced (see our earlier information here). Political agreement was already reached within the EU Council in March 2025.
The DAC 9 will therefore probably be formally adopted by the Council, acting as the sole standard-setter, once the legal-linguistic work is completed. It will then be published in the Official Journal and enter into force the day after.
Member States will have to implement DAC 9 by 31 December 2025. Countries that decide to postpone the implementation of the “Second Pillar Directive” are nevertheless obliged to implement the DAC 9 Directive within the same timeframe.
The Czech Republic is already preparing an amendment to Act No.164/2013 Coll., on International Cooperation in Tax Administration, for which the comment procedure has now ended. The amendment should implement the above-mentioned Directive DAC 9.
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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