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Czech Republic Publishes List of Non-Cooperative Jurisdictions for CFC Rules — Orbitax Tax News & Alerts

The Czech Republic has published Financial Bulletin No. 32/2021, which provides the list of non-cooperative jurisdictions for the purpose of the Czech Republic's controlled foreign company (CFC) rules. Under the CFC rules, specified income of a CFC is included in the taxable income of the controlling person(s) if the CFC does not have significant economic activity and is subject to tax at a rate less than half the Czech rate, or the CFC is in a non-cooperative jurisdiction according to the EU list at the end of the tax period.

The list has been provided considering the approval of the revised list adopted by the Council of the European Union on 5 October 2021, and includes the following:

  • For the period from 7 October 2020 to 25 February 2021: American Samoa, Anguilla, Barbados, Fiji, Guam, Palau, Panama, Samoa, Seychelles, Trinidad and Tobago, U.S. Virgin Islands, and Vanuatu;
  • For the period 26 February 2021 to 11 October 2021: American Samoa, Anguilla, Dominica, Fiji, Guam, Palau, Panama, Samoa, Seychelles, Trinidad and Tobago, U.S. Virgin Islands, and Vanuatu; and
  • From 12 October 2021: American Samoa, Fiji, Guam, Palau, Panama, Samoa, Trinidad and Tobago, U.S. Virgin Islands, and Vanuatu.

Note, the inclusion of CFC income based on the EU list of non-cooperative jurisdictions generally applies from 1 January 2021.