Finální formuláře k Pilíři 2 konečně na světě

The Collection of Laws has published the decree prescribing the forms for top-up tax filings, which sets out both the content structure of the filings themselves and the required filing format. Tax returns, as well as any information returns, will have to be submitted in XML format. We clearly highlighted ten practical points you need to know about Pillar Two filings in our April tax news.

Under the current wording of the Act and the decree, the standard set of filings for one Czech constituent entity includes two notifications of GIR filing in another jurisdiction (one for Czech top-up tax purposes and the other for the purpose of the income inclusion rule) and two tax returns (again, one for Czech top-up tax purposes and the other for the purpose of the income inclusion rule), provided that the specific conditions are met.

The data structure in a language other than Czech or containing different information regarding the reporting period (or other differences listed in the decree), will be regarded as compliant with the requirements of the decree.

The notifications for 2024 should be filed by 1 July 2026 if the group is within the scope of the Pillar Two rules and the reporting period is the calendar year. There is not much time left. Assessing whether the conditions for the transitional CbCR safe harbour are met may not always be straightforward – we outlined selected questions relevant to assessing eligibility for this safe harbour in our May tax alerts.

We are ready and able to help you with all matters related to Pillar Two.

Author:

Karel Hronek