Czech Republic: Amendments to Pillar Two rules signed by president
The bill includes amendments to the extension of filing deadlines.
A bill providing amendments to the “Act on Top-Up Taxes,” which implements the EU Minimum Tax Directive, was signed by the president and published in the official gazette on September 2, 2025.
The bill follows the version previously approved by the Czech Senate, including amendments to the extension of filing deadlines.
Notably, the bill confirms that, for the global anti-base erosion (GloBE) information return (GIR), the deadline is aligned with the OECD deadline, meaning that the GIR would need to be filed 15 months from the end of the reporting period (18 months for the transition year, i.e., June 30, 2026, for the 2024 calendar year). The same deadline applies for notifications due in case the GIR is filed in another jurisdiction where the group operates. Similarly, the bill confirms that local tax return filing and payment are due no later than 22 months after the end of the fiscal year, i.e., October 31, 2026.
For EU Minimum Tax Directive implementation purposes, the bill became effective on the day after its promulgation, with a retroactive effect for tax periods starting from December 31, 2023.
Read a September 2025 report prepared by the KPMG’s EU Tax Centre