Let us start with domestic news. On 29 December 2023, a new Act No. 416/2023 Coll. was published in the Collection of Laws, on Top-Up Taxes for large multinational groups and large domestic groups (the “Act”). The new Act will surely become a favourite item in the legislative search engine for some of us, at least for the first couple of years. Regular readers of our dReport will already know from previous articles that the Act transposes into Czech law the rules of the Pillar II global minimum tax, introduced in the EU through Directive 2022/2523 on ensuring a global minimum level of taxation of multinational enterprise groups and large domestic groups in the Union (the “Directive”).

The new Act came into effect on 31 December 2023 (in line with the Directive and within the transposition deadline), making us one of the few countries that will address “only” the ambiguities arising from the new global rules in relation to the first period of 2024, rather than the ambiguities associated with late implementation of the rules. Although the situation in other countries will of course complicate matters for Czech multinational groups as well.

Other countries are also continuously implementing the global minimum tax rules or partial obligations arising from them. You can keep up to date with the implementation developments in individual countries on our global tax news website tax@hand. You can also find a summary of developments in individual countries on our Pillar II platform.

The OECD has not fallen behind either, publishing its third administrative guidance before Christmas, which addresses further selected issues. It includes, for example, specifics arising from purchase price adjustments (PPAs) in reporting and qualified financial statements, additions to transitional CbC safe harbours, transition periods for groups with shorter reporting periods, etc. The OECD plans to issue a consolidated version of the administrative guidance published to date later this year or next year.