Multinational groups in the Czech Republic must file top-up tax returns by 1 July 2026 under new rules enforcing a 15% global minimum corporate tax rate. Â
The Czech Financial Administration released a statement on the Pillar Two global minimum tax forms recently approved under Decree No. 68/2026, published in the Official Gazette on 20 May 2026.
A key point of the statement is the confirmation that the Czech Republic has adopted the OECD’s common understanding issued on 18 May 2026, under which penalties are waived, and local GloBE Information Return (GIR) filing obligations will not be enforced.
The common understanding provides that jurisdictions applying the Global Minimum Tax from 2024 will waive penalties and may not enforce local GloBE Information Return (GIR) filing requirements where the GIR has been centrally filed in an eligible jurisdiction by the deadline and the required local notification has been submitted. However, this relief is conditional. If the centrally filed GIR is not exchanged between tax authorities by 31 December 2026, jurisdictions may reinstate local filing obligations and impose penalties to ensure access to the required information.
Submission deadlines and process
Czech top-up taxes, implemented under Act No. 416/2023 Coll., enforce a minimum corporate tax rate of 15% globally. Large multinational and domestic groups must file both a tax return and an information return if their effective tax rate falls short of this threshold.
For 2024 tax year filings, the information return is due by 1 July 2026, with the tax return following by 2 November 2026. Both must be submitted electronically through the MOJE danÄ› portal using standardised forms outlined in Decree No. 68/2026 Coll. The general timelines are 18 months for information returns and 22 months for tax returns from the end of the reporting period.
A single portal hosts both filings, though separate returns are required for each tax type. Submissions cannot be self-prepared documents; they must follow the prescribed structure with all mandatory data fields.
Centralised filing and exemptions
The Czech Financial Administration aligns with OECD guidance on Global Information Return (GIR) filing, which permits centralised submission across participating jurisdictions.
If a multinational group files its GIR centrally in one of 32 designated OECD jurisdictions by 30 June, Czech entities can satisfy local requirements through a notification of exemption rather than separate filings. This notification is completed via the information return form itself.
The Czech Republic qualifies as both a ready jurisdiction for centralised filing and is expected to participate in automatic information exchange by the end of 2026.
