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Fuel sales: new GFD interpretation of windfall tax

The Czech Statistical Office has updated the classification of activities according to the CZ-NACE. This may affect the scope of payers of windfall tax relating to the sale of fuel.

The General Financial Directorate (GFD) has modified its interpretation of activities falling under wholesale and retail sale of fuel and related retail or wholesale intermediary activities. This may have implications for determining whether a company was subject to windfall tax already for 2023. In some cases, the sale of fuel via fuel cards (in a buy-sell model) could qualify as fuel wholesale and therefore be subject to windfall tax for 2023.

Changes may also concern other areas like the regular sale of fuel from a public fuel station dispenser. Here, the type of customer may be decisive for the assessment of the activity’s nature (sales to professional customers under a contractual relationship constitute wholesale activity).

We therefore recommend fuel station operators re-examine whether they have become taxable on windfall profits. In the first stage, they have to test whether they have had income liable to windfall tax of at least CZK 2 billion for the first accounting period ending after 1 January 2021.

The financial administration's communication can be found here; the original 2023 classification here, and the updated classification of 3 May 2024 here.