Updates on double taxation treaties

On 15 October 2025, the Government of the Czech Republic authorized the signing of the Income and Capital Tax Treaty with Oman, which was agreed in May 2025.

News from the EU

The list of tax jurisdictions that the European Union considers to be non-cooperative remains unchanged

In October, the Council of the EU confirmed the existing list of non-cooperative jurisdictions for tax purpose. This list currently includes 11 countries: the U.S. Virgin Islands, American Samoa, Anguilla, Fiji, Guam, Palau, Panama, the Russian Federation, Samoa, Trinidad and Tobago, and Vanuatu. The EU list is intended to contribute to the promotion of tax good governance worldwide.

From the Czech point of view, this list is decisive in the application of specific rules concerning the taxation of controlled foreign companies (CFCs).

European Commission adopts work programme for 2026

The European Commission has adopted its work programme for 2026 entitled Europe’s Independence Moment”. In the area of direct taxation, it plans to introduce new initiatives, namely the “28th legal regime” and the tax omnibus. Both of these initiatives are intended to contribute to reducing administrative burdens and simplifying tax rules.

The European Commission has decided to withdraw the proposal for the “Unshell” Directive, aimed at preventing the misuse of shell entities, and  the “Debra” Directive, which was supposed to reduce the existing allowance of debt financing over equity financing and the tax deductibility of interest expenses. The proposal for a directive harmonizing transfer pricing rules across EU has also been withdrawn.

In the work programme, the European Commission continues to envisage the continuation of the legislative process on  the “BEFIT” Directive on a common framework for the calculation of the corporate tax base for groups of enterprises operating in the EU and  the Directive on the tax residence of micro, small and medium-sized enterprises. The process on the proposals for  a directive on the common system of digital services tax and  a directive laying down rules for the taxation of corporate entities with a significant digital presence in the EU is also to continue.

World news

The United States and Hungary have expressed interest in concluding a double tax treaty

The Hungarian government issued a press release informing that the representatives of Hungary and the United States of America have agreed to take bilateral steps leading to the concluding the double taxation treaty.

The previously concluded Double Tax Treaty of 1979 was terminated by the United States in 2022 with effect from 8 January 2023.

The French government has put forward a tax package aimed at taxing personal holding companies and large corporations

In October, the French government submitted a bill on changes in the tax area (a detailed overview can be found here). The most interesting measures proposed include:

New specific tax imposed on personal holding companies

The bill aims to introduce a tax on the value of assets of personal holding companies at a rate of 2%, which is intended to prevent tax evasion through the accumulation of retained earnings in these structures.

The basis for the new tax should be the value of the assets of these companies, i.e. the market value of their movable and immovable assets (with the exception of certain types of assets used for business purposes), part of the cash and non-controlling securities and shares in companies holding the above items.

Companies that meet the following conditions should be subject to tax:

• 33% or more of the voting or financial rights are held by a natural person jointly with his or her spouse and their parents, children or siblings; or such natural person de facto controls the company;
• the company’s total assets have a market value of EUR 5 million or more;
• more than 50% of the company’s operating and financial income is passive income, i.e. dividends, interest, royalties, copyrights, rent, or gains from the sale of assets generating such income; and
• the company is not directly or indirectly controlled by another company subject to the tax.

The scope of this tax would include:

• French companies subject to corporate tax; In such case, the tax would be paid directly by the company. The tax would be levied on these companies for the accounting period ending December 31, 2025 (or later).
• Foreign companies subject to similar tax abroad, which are controlled by a natural person – tax resident of France; In this case, the obligation to pay the tax would be borne by this controlling natural person. These companies would be subject to the new tax for the accounting period ending December 31, 2026 (or later).

Extension of the income tax surcharge measure for large companies

In 2025, a surcharge on corporate tax was introduced for large corporations. The bill envisages an extension of this measure by one year. In this extended period, a progressive element of taxation will be applied. Taxpayers with an annual turnover of less than €3 billion in 2025 and 2026 will be subject to a mark-up of 10.3%. The surcharge of 20.6% will then apply to taxpayers with a turnover above this limit in 2025 or 2026.