Top-up taxes (the OECD’s Pillar Two rules) represent one of the most significant developments in international taxation for multinational groups in recent years. The Czech Republic has incorporated these rules into its domestic legislation, creating new reporting and payment obligations for many Czech entities. The first filings relating to the 2024 fiscal year must be submitted by the end of June 2026.
If a Czech company, branch, or permanent establishment located in the Czech Republic is part of a group with consolidated revenues of at least EUR 750 million, it will fall within the scope of the Pillar Two rules. As the Czech Republic has implemented not only the global minimum tax rules but also a domestic top-up tax, affected entities face several compliance obligations.
What obligations apply and when?
For the 2024 fiscal year, Czech entities whose group uses the calendar year as its financial year will be required to submit the following:
By 30 June 2026
- A GloBE Information Return (GIR), or a notification that this obligation has been fulfilled by another group entity.
- An information return relating to the Czech domestic top-up tax, or a notification that this obligation has been fulfilled through the filing of the global GIR referred to in point 1.
By 31 October 2026
- A tax return for the allocated top-up tax.
- A tax return for the Czech domestic top-up tax.
The Czech tax authorities have already published the forms relating to notifications and tax returns.
However, certain questions remain unresolved regarding the structure and filing process of the information returns themselves, for which the tax authorities will not provide a dedicated form.
It is also necessary to ensure that the GIR is filed by an entity located in a jurisdiction that has adopted and committed to the exchange of information framework applicable to GIR filings. Only in such a case can the filing obligation be replaced by the notification referred to above.
