Legislative Background and Amendment Grounds
The Czech Senate has approved a key amendment to the Top-Up Tax Act, extending the deadlines for filing the information return and tax return for the Czech Top-Up Tax. This reform aims to align filing times and grant taxpayers more leeway to adapt to the new obligations requirements imposed by the OECD’s Pillar Two.
Initially, the filing deadlines were set at ten months after the end of the tax period-for 2024, i.e., in October 2025. The reform extends this deadline to 15 months for the first filing of the information statement, while 22 months are established for the tax return, which transfers the deadlines to June 30, 2026, and October 31, 2026, respectively.
Operational and Tax Implications
The extension of deadlines reflects the complexity of implementing the GloBE (Global Anti-Base Erosion) model and tax compliance in countries that have recently adopted the minimum tax regulations. The need to prepare forms included in both the top-up tax return and the GloBE Information Return, under the OECD standards, supports the additional time required by taxpayers and tax authorities.
This additional period also allows the government to finalize the design and implementation of standardized, possibly unified forms, strengthening the consistency of reported data and facilitating compliance. On the other hand, aligning the deadlines for both types of returns contributes to more organized and efficient management from both the taxpayer’s and the tax authority’s perspective.
Relevance for Global Minimum Tax Administration
The approved extension is not merely operational: it is crucial to transition to more transparent and cooperative tax auditing. The additional time allows authorities to finalize their processing systems, such as automatic data exchange (similar to DAC9), and consolidation with other international tax schemes.
Simultaneously, it provides taxpayers with the necessary time to organize internally their compliance structure, gather the required consolidated information, and coordinate with specialized advisors. In tax divisions where the global minimum tax and Transfer Pricing converge, this extension becomes particularly relevant.
Conclusion
The extension of filing deadlines for the Top-Up Tax in the Czech Republic marks a proactive step toward ensuring an orderly transition to a more complex global tax regime. The extension of the deadlines for the information and tax returns by 5 and 12 months, respectively, provides reasonable leeway for both taxpayers and authorities to adjust their processes, implement the correct forms, and comply with international standards. This measure demonstrates fiscal pragmatism and reinforces the reliability of the Czech tax system in the context of the global minimum tax.
Source: https://danovky.cz/en/news/detail/1699