On 18 May 2026, the OECD published an announcement to support the implementation of the Global Minimum Tax and mitigate the impact of any potential delays in the availability of fully operational filing portals or exchange relationships in implementing jurisdictions, in particular a common understanding to preserve the administrative and compliance benefits of the central filing mechanism for the GloBE Information Return (“GIR”) for the first reporting period of 2024.
The OECD stated in its announcement that jurisdictions implementing the Top-up Tax rules from 2024 have agreed to publish a list of jurisdictions expected to have a fully operational GIR filing portal in place by 31 May 2026, and use mechanisms available under their respective domestic laws to waive penalties or suspend enforcement of local GIR filing obligations before the relevant GIR exchange deadline where the GIR has been centrally filed in any one of the listed jurisdictions.
Following this initiative, the Czech Tax Administration issued the following statement:
“The 2024 Implementing Jurisdictions agreed that in the case of central filing (i.e. filing by one entity on behalf of the entire group in a single jurisdiction), they will either refrain from enforcing local filing prior to the deadline for automatic exchange of information or waive penalties for non-compliance with this obligation, under the following conditions:
I. The GIR is centrally filed by 30 June in one of the 32 jurisdictions listed in the appendix to the OECD document,
II. At the same time, local entities in the local jurisdiction, i.e. the Czech Republic, notify such central GIR filing in one of the 31 jurisdictions (i.e. all listed jurisdictions other than the Czech Republic) by 30 June. The notification obligation may be fulfilled through the Notification on the Exemption from Filing the GloBE Information Return Form.
The Czech Republic is included in the OECD document both among jurisdictions prepared for central GIR filing and among jurisdictions that are expected to be ready to exchange the relevant information by the end of 2026.”
Based on the above statement, we infer that if a GIR is filed in a jurisdiction listed in the appendix to the OECD document under the conditions described above, it should be possible to apply the exemption and instead of filing the GIR itself, submit only the related notification.
In this context, we note that the Czech Financial Administration’s statement does not address the procedure concerning the Czech Information Return.
Additional practical updates regarding Top-up Taxes:
On 20 May 2026, a decree on Top-up Tax filing forms was published in the Collection of Laws, establishing the final forms relating to Top-up Taxes. However, the electronic forms are not yet available and are expected to appear in the coming days.
The Czech Tax Administration has also commented on the specific treatment applicable to Cyprus, which is expected to be clarified further in the near future.
At the same time, the OECD/G20 Inclusive Framework on BEPS published additional Administrative Guidance regarding the application of the Transitional UTPR Safe Harbour and updated the Central Record for purposes of the Global Minimum Tax.
Should you require assistance with assessing your obligations or preparing filings related to Top-up Taxes, please do not hesitate to contact us.
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