Top-up tax forms published
The Czech Financial Administration has published the filing forms relating to the Czech qualified domestic top-up tax and the GloBE top-up tax which were introduced in the Czech Republic as of 2024 under Act No…
Double taxation treaty with Kosovo
After many years of discussions, the treaty between the Czech Republic and the Republic of Kosovo on the avoidance of double taxation and prevention of tax evasion with respect to taxes on income entered into force on 24 July 2023. The treaty was originally signed in Pristina on 26 November 2013 but due to the lengthy legislative process in the Czech Republic, the treaty was presented in several election periods.
The treaty regulates mutual relations in the field of personal income tax and corporate income tax in the Czech Republic and in the area of personal income tax and corporate income tax in Kosovo.
Key points of the treaty:
- A permanent establishment (PE) includes the concept of a so-called service PE (if the relevant activities continue for a period or periods exceeding six months in aggregate in any twelve-month period).
- Dividends may also be taxed in the source state – the tax thus imposed will not exceed:
- 5 % of the dividend gross amount, if the beneficial owner is a company that directly holds at least 25 % of the capital of the company paying the dividend.
- 15 % of the dividend gross amount in all other cases.
- Interest is taxable only in the state of residence.
- Industrial royalties are also taxable in the source state – the tax so imposed will not exceed 10% of the gross royalty amount.
- Gains from the alienation of property in the case of shares do not contain a real estate clause – they are only taxed in the resident state.
The provisions of this Agreement will be implemented as follows:
a) in the case of taxes withheld from the taxpayer’s income, on income paid or credited on or after 1 January 2024;
b) in the case of other income taxes, on income for each tax year beginning on or after 1 January 2024.
