On 7 May 2025, the Czech government approved a draft amendment to Act No. 164/2013 Coll., on International Cooperation in Tax Administration and on Amendments to Related Acts, introducing two key innovations regarding crypto-assets and the taxation of large multinational groups.
Annual crypto-asset reporting
Service providers related to crypto-assets will be newly required to submit to the competent authorities, once a year, aggregate reports on holders of these assets and on all transactions they carried out on their behalf. Until now, authorities could only request this information on a case-by-case basis. The new legislation establishes regular automatic reporting, which will significantly simplify and accelerate access to the data needed for tax control.
The explanatory memorandum emphasises that "the obtained information will allow more efficient identification of risks in fulfilling tax obligations and their control in the relevant area", thereby strengthening the financial administration's ability to detect tax evasion and risky behaviour in crypto-asset transactions.
Automatic exchange of information for the top-up tax
The amendment also introduces an automatic exchange of information related to the so-called top-up tax, designed to ensure a uniform minimum level of taxation for large multinational and domestic groups. The tax will apply to companies that have achieved consolidated revenues of at least EUR 750 million (approximately CZK 18.7 billion) in two of the last four years and operate in the Czech market. If their effective tax rate in the Czech Republic does not reach 15%, the tax authority will assess a top-up tax to guarantee at least a 15% minimum rate.
Transposition of European legislation
The Ministry of Finance notes that all introduced changes merely transpose European directives—specifically the DAC 8 Directive (automatic exchange of information on crypto-asset transactions) and the proposed DAC 9 Directive (amendments to tax cooperation)—into Czech law. Since the European regulations are set to take effect on 1 January 2026, the Ministry recommends that the Chamber of Deputies approve the draft in its first reading.
Note: The draft is now heading to the approval process in the Czech Parliament. Its adoption will prepare the Czech Republic for a unified regime of international tax cooperation, streamline oversight of the crypto-asset market, and ensure fair taxation of large multinational corporations.
By Lukas Tomanek, Junior Lawyer, JSK Law firm, PONTES
