On 13 February 2025, the Czech Chamber of Deputies passed the first reading of Parliamentary Document No. 783, which proposes amendments to Act No. 416/2023 Coll., on Top-Up Taxes For Large Multinational Groups And Large Domestic Groups (the “Top-Up Taxes Act”). This Act came into force in the Czech Republic on 31 December 2023 and the planned amendment introduces several positive changes, including an extension of the deadlines for filing the information return and the tax return on the Czech top-up tax. Under the proposed changes, the deadlines for the first reporting period should be no sooner than 30 June 2026. However, if the amendment is not approved during the current term of the Chamber of Deputies, the Czech top-up tax taxpayers could already face related obligations in 2025.
Deadlines for Filing Information Returns and Tax Returns
Under the current version of the Top-Up Taxes Act, the taxpayers subject to the Czech top-up tax must file their top-up tax return no later than 10 months after the end of the taxable period. Within the same deadline, the Czech top-up tax taxpayers are also required to submit an information return on the Czech top-up tax. The proposed amendment to the Top-Up Taxes Act aims to extend the deadline for filing the Czech top-up tax return to 22 months after the end of the taxable period and the deadline for filing the Czech top-up tax information return to 15 months after the end of the taxable period, and to 18 months in case of the initial period of a group.
As the second reading of the proposed amendment has not yet taken place in the Chamber of Deputies, it remains uncertain whether it will be approved during the current parliamentary term. Consequently, it is unclear whether the amendment will be passed in time to extend the relevant deadlines for the Czech top-up tax under the current version of the Act. However, the Chamber of Deputies has approved a proposal to shorten the period between the first and second reading of the amendment to 30 days, which could potentially accelerate the legislative process. If the amendment is not approved in time, it is expected that the tax administrator will issue a methodological guidance on the matter, as the relevant filing forms for the Czech top-up tax are not yet available.
Given the above, it is important to prepare for the possibility that the Czech top-up tax taxpayers may be required to file both the tax return and the information return on the Czech top-up tax within 10 months after the end of the taxable period (for some, already in 2025).
We will continue to monitor the approval process of the proposed amendment on your behalf. Additionally, we are keeping an eye on any actions taken by the tax administrator regarding the potential release of guidance and templates for submitting tax returns and the information returns on the Czech top-up tax.
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