On 20 May, 2025, the Czech Republic issued Decree No. 68/2026 Coll which prescribes the content structure and electronic format for the Czech Pillar Two tax return and the Czech Pillar Two information return. The decree became effective on 21 May 2026.
It provides that the tax return structure is set out in Appendix 1, the information return structure is set out in Appendix 2, and the required electronic form filings may be submitted only in XML format.
For a calendar-year 2024 group, the key deadlines are: the central GIR deadline is 30 June 2026, while the Czech local information return deadline published by the Czech Financial Administration is 1 July 2026. A Czech entity relying on central GIR filing outside Czechia must also notify the Czech tax authority by 30 June 2026. The Czech Pillar Two tax returns are due 2 November 2026.
Decree No. 68/2026 Coll sets the content structure and format of electronic form filings for Czech Pillar Two top-up taxes. It was issued under the Czech tax procedure framework and implements the relevant EU administrative cooperation rules for Pillar Two reporting, Council Directive (EU) 2025/872, (DAC9).
The decree therefore has three core functions:
| Function | Practical effect |
|---|---|
| It identifies the required filing structures | Tax return in Appendix 1; information return in Appendix 2 |
| It fixes the electronic format | XML only |
| It aligns the Czech filing structure with EU/OECD reporting | The information return follows the GIR-style data framework used for Pillar Two exchange and risk assessment |
The decree also includes a flexibility rule. A data structure published by the tax authority can still be treated as corresponding to the prescribed content structure even where text parts are in a language other than Czech, where the period information differs, or where deviations are necessary because of domestic law, directly applicable EU law, the OECD Model Rules, or the OECD implementation framework.
The two main filings
The decree covers two distinct filings: the tax return and the information return.
The tax return is the self-assessment filing for Czech top-up tax payable. It captures taxpayer identification, group-level data, ultimate parent entity details, whether the period is the group’s initial period, whether the tax amount is nil, and the relevant domestic or assigned top-up tax amounts. The return separates domestic top-up tax from assigned top-up tax, and the assigned top-up tax section is further divided between the income inclusion rule and the undertaxed profits rule.
The information return is the Czech local GIR-equivalent filing. It contains detailed Pillar Two information about the group, the filing entity, the ultimate parent entity, the accounting framework, the reporting currency, the ownership and entity structure, safe harbours, exclusions, jurisdictional computations, covered taxes, effective tax rates, and top-up tax allocations.
The tax return determines the Czech tax liability. The information return provides the detailed Pillar Two data that supports administration, review, risk assessment, and exchange of information.
Appendix 1 prescribes the structure of the Czech Pillar Two tax return. The return requires basic taxpayer data, group data, ultimate parent entity identification, and then the relevant tax computations.
The key computation split is:
| Tax return section | What it covers |
|---|---|
| Domestic top-up tax section | Czech domestic minimum top-up tax amounts |
| Assigned top-up tax section | Top-up tax assigned under the income inclusion rule and the undertaxed profits rule |
| Amended return section | Last known tax, newly determined tax, and increase or decrease |
Although there is one tax return form, the decree instructions and the Czech Financial Administration notice make clear that a taxpayer must file separately for domestic top-up tax and assigned top-up tax. One completion of the form cannot cover both taxes at the same time.
The decree also anticipates that Pillar Two data may be prepared under OECD model-rule logic but require adjustment for Czech-law purposes. Where information return amounts prepared under model rules differ from amounts that would arise under Czech law, the taxpayer may need to explain the differences and provide supporting computations for the Czech tax return.
Information return structure under Appendix 2
Appendix 2 is the most substantial part of the decree because it prescribes the Czech Pillar Two information return. This is the filing that corresponds most closely to the GIR.
The information return begins with group-wide data, including the filing entity, reporting period, accounting framework, reporting currency, ultimate parent entity, corporate structure, constituent entities, ownership information, and entity status information.
It then moves into jurisdictional information and computations. The structure includes safe harbour and exclusion data, effective tax rate calculations, qualifying income or loss, adjusted covered taxes, deferred tax adjustments, additional top-up tax, qualified domestic top-up tax, and allocations under the income inclusion rule and undertaxed profits rule.
This structure is consistent with the wider OECD and EU design of Pillar Two reporting. The OECD central filing document states that in-scope groups must file the GIR for the 2024 fiscal year by 30 June 2026, and that the central filing jurisdiction will then exchange relevant GIR information with other implementing jurisdictions by 31 December 2026.
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