Czech Republic: Updated domestic list of non-cooperative jurisdictions regarding CFC rules
Turks and Caicos Islands and Vietnam added; Antigua and Barbuda, Fiji, and Samoa removed
A revised list of non-cooperative jurisdictions concerning the Czech Republic’s controlled foreign company (CFC) rules aligns with the EU list of non-cooperative jurisdictions (Annex I) adopted by the Council of the EU on February 17, 2026, and includes American Samoa, Anguilla, Guam, Palau, Panama, Russia, Turks and Caicos Islands, U.S. Virgin Islands, Vanuatu, and Vietnam, effective March 6, 2026.
Compared to the previous list effective from February 26, 2024, to March 5, 2026, Antigua and Barbuda, Fiji, and Samoa were removed, while Turks and Caicos Islands and Vietnam were added.
According to Czech CFC rules, a controlled company that is a tax resident of a state on the Czech list of non-cooperative jurisdictions, or a permanent establishment in such a state, is automatically considered a CFC. This means controlled subsidiaries in these countries are taxed at the level of the controlling entities, with tax levied on both passive and active income.
Read an April 2026 report prepared by KPMG’s EU Tax Centre