Beneficial owners - Czech debt securities

26.11.2015

The following types of beneficial owner are recognised for tax purposes in Czech Republic:

  • Residents of a DTT country
  • EU/EEA residents
  • EU/EEA pension funds
  • Central banks
  • International and Supranational Organisations
  • Czech legal entities
  • Czech individuals

Residents of Double Taxation Treaty (DTT) countries

The beneficial owners that are residents in a country which has signed a DTT with Czech Republic may benefit from a reduced tax rate on interests payments. The maximum withholding tax rates are defined in the DTT list.

Important note:

  • Residents of a country which has not signed any DTT with Czech Republic, but which has signed a treaty on the exchange of information with Czech Republic may benefit from a 15% reduced tax rate.
  • Residents of a country which has signed a DTT with Czech Republic granting a tax rate higher than 15% may benefit from the maximum rate of 15%.

EU/EEA residents

The beneficial owners that are residents of the EU/EEA, in a country which has not signed any DTT with Czech Republic, may benefit from a 15% reduced tax rate.

EU/EEA Pension funds

EU/EEA Pension funds may benefit from a tax exemption.

Central Banks

Central Banks may benefit from tax exemption if it is granted by the DTT signed between Czech Republic and the Central Bank’s country of residence.

Supranational and International organisations

Beneficial owners that are supranational/international organisations may benefit from a tax exemption.

Czech legal entities

Beneficial owners that are legal entities resident in Czech Republic for tax purposes may benefit from a tax exemption on interests.

Such beneficial owners are under the obligation to comply through their annual fiscal declaration with all legal and regulatory requirements imposed by Czech law in respect of withholding tax.

Czech individuals

Individual beneficial owners resident in Czech Republic for tax purposes may benefit from a 15% reduced tax rate on interests payments.

Such beneficial owners are under the obligation to comply through their annual fiscal declaration with all legal and regulatory requirements imposed by Czech law in respect of withholding tax.