The year 2026 marks an important milestone for companies subject to the Top-up Tax Act (Pillar Two). For the first time, affected entities are required to submit Top-up Tax Information Returns followed by Top-up Tax Returns. In the Czech Republic, these obligations apply to both the Allocated Top-up Tax and the Czech Domestic Top-up Tax.
The First Deadline Has Already Passed
For groups whose financial year corresponds to the calendar year, the deadline for submitting the Top-up Tax Information Return expired on 30 June 2026.
The next key obligation is to file the tax return for the Czech Domestic Top-up Tax or the Allocated Top-up Tax by 2 November 2026.
Electronic Filing and New Forms
The Ministry of Finance has issued Decree No. 68/2026 Coll., which establishes the mandatory structure of filing forms for top-up taxes. All filings must be submitted electronically using the prescribed forms. The Information Return must also include an XML attachment that complies with the OECD standard for the GloBE Information Return (GIR).
Exemption Option
Where the statutory conditions are met, the Information Return may be replaced by a notification claiming an exemption from the filing obligation. This option is available where the Information Return is submitted by another group entity located abroad and the conditions for the international exchange of information are satisfied.
Recommendation for Affected Groups
Companies subject to the top-up tax rules should not delay the preparation of their filings. In addition to verifying the scope of their reporting obligations, they should ensure the timely availability of all required data, prepare XML attachments in accordance with the OECD standard, and verify the accuracy of the reported information. These first filings represent an entirely new administrative obligation requiring careful preparation and close coordination across the entire corporate group.
