Based on the discussions with the Czech Tax Office and also the Czech National Bank (CNB) in its role of the paying agent for Czech government bonds and T-Bills, we hereby inform you that the CNB communicated they will no longer accept Beneficial Owner Declaration (BOD) as a one-time document. The BOD will be required for each income/redemption payment and should be issued after the record date. An alternative is for the custodian (UniCredit) to provide a declaration that all valid documents (including BOD) are in place and will be delivered upon request should the Tax Office inspect the paying agent on site.
There are different approaches of local custodians in the market, since local laws and regulations are not specific about the age of the BOD. UniCredit Bank Czech Republic and Slovakia, a.s. decided to apply less strict approach and we ask our clients to deliver the BOD not older than 3 calendar years following the year when the BOD was issued (e.g. in case we receive the BOD in August 2018, the BOD will be valid till 31 December 2021).
In order to act consistently, this approach will be applied to all income/ redemption payments, i.e. not only in cases where the CNB acts as a paying agent. If applicable, the updated BOD should be delivered to UniCredit no later than 31 December 2018. After this date, in the absence of the updated BOD, the maximum tax rate, i.e. 35%, will be applied.
Should you need a list of BOD on our files, please do not hesitate to contact our operations team at email@example.com.
Impact on investors: Investors are asked to deliver the BOD not older than 3 years following the year of issuance.