Trading branches of foreign corporations are usually taxable on actual profits as is recorded in their bookkeeping, in the same manner as Czech companies. Non-trading branches of foreign companies may be liable to corporate income tax on anticipated profits. The basis on which anticipated profits are calculated must be negotiated in advance with the local Tax Authority.
Dividends, interest, royalties and rental payments paid by a Czech subsidiary to foreign parent companies are generally subject to withholding tax, except where these payments are exempt under the EU Directives regime or Double Tax Treaties.
Dividends are generally subject to 15% withholding tax. However, dividends from EU subsidiaries are exempt on condition of at least 10% share of capital for at least 12 months. On meeting certain conditions even the dividends from non-EU subsidiaries can be exempt.