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 f…
Czech Republic–Russia: limitations on the application of the double taxation treaty
On 29 September 2023, a Notice of the Ministry of Foreign Affairs on the suspension of the application of Articles 5 to 22 and 24 of the Treaty between the Government of the Czech Republic and the Government of…
In brief from international taxation [September 2023]
The Pillar Two implementation process, which introduces a minimum taxation rate of 15% for multinational groups and large domestic groups, is continuing in EU countries. The most recent developments have been i…
OECD Pillar Two updates
On 17 July 2023, the OECD/G20 Inclusive Framework on BEPS published a package of documents on the implementation of the Pillar Two global minimum tax rules (“Pillar Two”). The package includes additional admini…
Global minimum tax: draft transposition approved by the Czech government
On 16 August 2023, the Government of the Czech Republic approved the new bill of the Top-up Taxes Act to ensure a minimum level of taxation of large-scale multinational and domestic groups. This is the transpos…
Russia has suspended most articles of double tax treaties with unfriendly countries, including the Czech Republic
In March this year, the Russian Ministry of Finance and the Russian Foreign Ministry came up with a joint proposal to suspend double tax treaties with all "unfriendly" countries. Subsequently, the ministries tu…
In brief from international taxation [June 2023]
In the UK, the Netherlands, Guernsey, Jersey and the Isle of Man, the legislative processes related to Pillar Two of the OECD’s international tax reform continue. The Canton of Geneva will replace the municipal…
Global minimum tax: draft Czech legislation under comment procedure
A new draft act on the top-up tax for the purpose of ensuring a minimum level of taxation for large-scale multinational and large-scale domestic groups (i.e. groups with consolidated annual revenues exceeding t…
In brief from international taxation [May 2023]
What is the latest news in international taxation? CJEU rules that the German taxation of real estate funds is not compatible with EU law. Switzerland is holding a referendum on global minimum tax. From next Ja…