TAXATION OF INDIVIDUALS IN THE CZECH REPUBLIC

1. TAXATION OF INDIVIDUALS IN THE CZECH REPUBLIC TAXATION

2. Individuals are subject to income tax. Taxable income and tax liability of individuals are determined under the Income Tax Law. TAXATION

3. Taxable persons • Residents • Non-residents TAXATION

4. 1. Residents An individual is considered to be a resident of the Czech Republic: • permanent home (residential address) • > 183 days in the Czech Republic in relevant calendar year, except stay for studies or medical treatment TAXATION

5. Taxable income Resident individuals are subject to tax on their worldwide income received in monetary or non-monetary income. TAXATION

6. Following income and capital gains are subject to income tax: • employment income (salary/ benefits in kind, pension, director’s remuneration) • business and professional income (royalties and licence fees) • income from capital (investment income, capital gains) • rental income and • other income TAXATION

7. Other income: • income from occasional activities > CZK 20,000 (2015: 30,000) • capital gains on the sale of non-business assets, unless exempt • sale of property rights • alimony payments and pensions if not exempt • settlement payments and liquidation proceeds of companies and partnerships TAXATION

8. Every individual is taxed separately. The net result (income minus deductible expenses) is subject to a flat tax rate + solidarity surcharcharge.Certain items of income are taxed separately by way of a final withholding tax rate. TAXATION

9. Personal deductions, allowances • Deductions • Tax credits TAXATION

10. A. Deductions Following items are deductible: • donations for charitable purposes, described by law and deductible after a threshold. Including established in EU, Norway and Iceland. • mortgage interest for the main residence up to CZK 300,000 per year • premiums paid for private life/state insurance up to CZK 12,000 per year. TAXATION

11. B. Tax credits Resident and non-resident individuals may deduct from their aggregate income a at least a basic personal allowance for spouse and children. The credits may only be used (deducted) up to taxpayer’s tax liability. As of 2015 a tax credit of CZK 3,000. TAXATION

12. Losses Any negative result of the category of employment, capital and other income cannot be negative. Any negative result of the category of business and professional income can be set off against a positive result of rental income. If the aggregate income (excluding employment income, capital income and other income) is negative, losses may be carried forward for five taxable periods. TAXATION

13. Tax rates The tax rates consist of a flat rate of 15%. (As of 2015 19%.) For the tax years 2013-2015 an additional 7% solidarity surcharge applies, which exceeds four times the annual average salary (CZK 1,242,432) TAXATION

14. Withholding tax Following items of income derived by residents from domestic sources and are subject to a final withholding tax at a rate of 15%: TAXATION

15. dividends and other distributions • interest on bonds • Interest and other yields on money held in savings accounts, deposit accounts or non-business current accounts • Benefits from a state-contributory supplementary pension insurance or from a private life insurance, reduced by the premiums paid. TAXATION

16. From 2015 dividends and other profit distributions derived by resident individuals from resident companies will be exempt. TAXATION

17. Taxable period Income tax is assessed annually. The taxable period is generally the calendar year. Individuals with an aggregate income exceeding CZK 15,000 must file a tax return. Entrepreneurs deriving income from agriculture or trade may choose a different financial year upon approval of the authorities. TAXATION

18. 2. Non-residents Individuals who do not have their permanent residence in the Czech Republic are treated as non-residents. TAXATION

19. The income of non-residents is generally taxed (15% or 35%) according to the rules applicable to residents, unless a law or tax treaty provides otherwise. If 90% is derived from Czech sources the non-resident is entitled to deductions which residents are entitled to. As of 2015 only for EU member states incl. Norway and Iceland. TAXATION

20. Non-residents are entitled to the basic personal tax credit. TAXATION

21. Non-residents are subject to the general withholding tax unless special rules apply: TAXATION

22. Remuneration paid to non-resident members of statutory executive and supervisory bodies of resident legal entities is subject to a final withholding tax at a rate of 15 or 35%. TAXATION

23. Income from independent activities and from services provided in the Czech Republic is subject to a final withholding tax at a rate of 15% or 35%. TAXATION

24. A rate of 15% or 35% applies to royalties and to income from the leasing of movable assets. TAXATION

25. Scheme income tax • Income minus deductions • Income tax (flat & withholding tax) • Less: tax credits • Payable/refundable income tax. TAXATION

26. Social Security • Employees and self-employed persons are liable to social security contributions. • Contribution for employed: 11% • Contribution for self-employed: 45% TAXATION