Top-up taxes apply to Czech entities that are members of a large multinational or large domestic group whose consolidated revenues, as reported in the consolidated financial statements of the ultimate parent entity, reached at least EUR 750 million in two out of the four immediately preceding fiscal periods.

In this context, we would like to remind you of the key filing deadlines for top-up taxes for the 2024 calendar year

*Under the conditions stipulated by law, the information return may be replaced by a notification of exemption from the obligation to file a top-up tax information return.

It is worth noting that no XML form is available for the information returns, whether for the Czech domestic top-up tax or the GloBE top-up tax. The relevant group must therefore prepare the XML file independently. For the actual submission, taxpayers use the so-called “cover form” prepared by the Czech Financial Administration for this purpose. The same “cover form” may also be used to submit a notification of exemption from the obligation to file a top-up tax information return.

The topic of filing forms is also connected to the amendment of Act No. 164/2013 Coll., on International Cooperation in Tax Administration and on Amendments to Related Acts, currently being discussed by the Czech Parliament as Parliamentary Document No. 98. The amendment introduces a new section governing the automatic exchange of information on top-up taxes within the EU, following DAC 9, i.e. Council Directive (EU) 2025/872 of 14 April 2025 amending Directive 2011/16/EU on administrative cooperation in the field of taxation.

The active automatic exchange of top-up tax information returns is a key requirement for applying the exemption from the obligation to file a top-up tax information return in the Czech Republic. Where the exemption applies, the taxpayer will only submit a notification identifying the entity that filed the GloBE top-up tax information return abroad.

In this regard, it is important to note that the Czech Republic has not yet acceded to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information (GIR MCAA). Without this agreement, the exchange of information returns with non-EU jurisdictions is currently not possible in the Czech Republic. As a result, certain Czech entities may still be required to file information returns locally in the Czech Republic because they will not meet the conditions for the exemption.

Should you require assistance in assessing your obligations or preparing filings related to top-up taxes, please do not hesitate to contact us.