The Czech Ministry of Finance issued a communiqué announcing a draft law on the implementation of the Pillar II global minimum tax in accordance with Council Directive (EU) 2022/2523 of 14 December 2022 (previous scope). According to the announcement, the draft law is purely a transposition regulation that reflects the directive.
This includes the introduction of the Pillar 2 income inclusion rule (IIR) and the under-taxed payment/profit rule (UTPR) to ensure a minimum taxation level of 15 per cent for MNE groups with annual consolidated revenues of at least €750 million in at least two of the previous four tax years.
The proposal also includes the introduction of a qualified national minimum top-up tax (QDMTT) for members of covered groups, which the ministry refers to as the Czech top-up tax. The draft law, which should enter into force on 31 December 2023, has been approved by the government and must now be discussed and approved by both chambers of parliament and signed by the president.
