In case of CFCs in jurisdictions that are not included on the EU list of non-cooperative jurisdiction for tax purposes, the CFC tax applies when the tax of the CFC is less than half of the tax that would have been imposed if it had been a tax resident of the Czech Republic. In geneal, the triggering rate would be 10.5%.

In case of CFCs located in jurisdictions that are included on the EU list of non-cooperative jurisdiction for tax purposes, the CFC tax has no triggering rate.