Legal services:

Comprehensive legal solutions for contracts, disputes, and compliance. Our expert team ensures legal protection and strategic guidance for your business.

AML consulting:

Specialised AML consulting to develop and maintain robust anti-money laundering policies. We assess risks, offer ongoing support and provide tailored AML services.

Obtaining a crypto license:

We offer licensing and ongoing support for your crypto-business. We also offer licences in the most popular jurisdictions.

Registration of legal entities:

Efficient legal entity registration support. We manage documentation and interaction with the authorities, ensuring a seamless process for establishing your business.

Opening bank accounts:

We facilitate the opening of bank accounts through our extensive network of partners (European banks). Hassle-free process, tailored to your business needs.

COREDO TEAM

Nikita Veremeev
Nikita Veremeev
CEO
Pavel Kos
Pavel Kos
Head of the legal department
Grigorii Lutcenko
Grigorii Lutcenko
Head of AML department
Annet Abdurzakova
Annet Abdurzakova
Head of the Customer Success Department
Basang Ungunov
Basang Ungunov
Lawyer at Legal Department
Egor Pykalev
Egor Pykalev
AML consultant
Yulia Zhidikhanova
Yulia Zhidikhanova
Customer Success Associate
Pavel Batsulin
Pavel Batsulin
AML consultant
Diana Alchaeva
Diana Alchaeva
Customer Success Associate
Johann Schneider
Johann Schneider
Lawyer
Daniil Saprykin
Daniil Saprykin
Customer Success Associate

Our clients

COREDO’s clients are manufacturers, traders and financial companies, as well as wealthy clients from European and CIS countries.

Effective communication and fast project realisation guarantee satisfaction of our customers.

Exactly
Unitpay
Grispay
Newreality
Chicrypto
Xchanger
CONVERTIQ
Crypto Engine
Pion
In 2025, the Czech Republic once again confirms its status as one of the most attractive jurisdictions for international investors: according to the European Commission, foreign direct investment in the country increased by 18% over the past year, and the average time to obtain a permit for a major investment project has been reduced to 60 days thanks to the introduction of investment passports. But behind these figures lies a much deeper question: why is the Czech Republic becoming the strategic choice for those who build a business aimed at long-term tax efficiency and transparency?
Many entrepreneurs face a paradox: on the one hand, they need access to EU markets and a stable legal environment, and on the other, they are looking for ways to minimize their tax burden and obtain guarantees for investment protection. In a context of constant changes to tax legislation and tightening disclosure requirements, the choice of jurisdiction becomes critically important.

In this article I will describe in detail how the COREDO team helps investors not only to register a company in the Czech Republic, but also to build an optimal tax and corporate structure, using all available benefits, subsidies and capital protection tools. If you are looking not just for an overview but for a practical guide to effective investing in the Czech Republic – I recommend reading to the end: you will get answers to key questions and learn about strategies that really work.

Main taxes for investment companies in the Czech Republic

Illustration for the section ‘Main taxes for investment companies in the Czech Republic’ in the article ‘Investment companies of the Czech Republic - taxation and advantages for investors’
In COREDO’s practice we regularly encounter questions about the tax structure in the Czech Republic. Understanding tax obligations is the foundation for making strategic decisions.

Corporate tax rates and features for 2025

In 2025, the corporate tax in the Czech Republic remains at 21%. This rate applies to all resident companies, as well as to foreign companies conducting activities through a permanent establishment. It is important to note that the tax base is formed on the basis of worldwide income if a company is recognized as a tax resident of the Czech Republic. For large companies with turnover exceeding €750 million, a minimum tax of 15% is being introduced, which reflects European trends towards tightening tax discipline and combating aggressive tax planning.

COREDO’s experience shows: by properly structuring a business and using international agreements on the avoidance of double taxation, you can significantly reduce the effective tax burden, particularly for holding and investment structures.

Value Added Tax (VAT) for investors

VAT in the Czech Republic is set at 21%, with reduced rates of 10% and 15% for certain categories of socially significant goods and services. Accelerated VAT refund procedures are provided for export-oriented companies, which is especially relevant for technology projects and startups operating in international markets.

A solution developed by COREDO for a number of clients allowed them to optimize their supply structure and achieve regular VAT refunds within 30–45 days, which significantly improved cash flow and increased the investment attractiveness of the business.

Tax on dividends and capital gains

Dividends paid by Czech companies are subject to a withholding tax (Srážková daň) at a rate of 15%. However, for EU parent companies holding at least 10% of the shares for 12 months, a participation exemption applies, allowing dividends to be completely exempt from taxation. Capital gains are taxed at the corporate tax rate, but exemptions are possible under certain conditions, for example, on the sale of shares that have been held for more than three years.

COREDO’s practice confirms: proper structuring of share ownership and timely obtaining of parent company status can significantly minimize taxes on dividends and capital gains, which is especially important for investment funds and holdings.

Tax incentives for foreign investors

Illustration for the section 'Tax incentives for foreign investors' in the article 'Investment companies of the Czech Republic - taxation and advantages for investors'
Czech legislation offers a wide range of tax benefits and incentives aimed at attracting long-term investments, especially in innovative and technological projects.

Profit tax exemption for up to 10 years

For new investments in priority sectors (technology, scientific research, manufacturing), a profit tax exemption regime of up to 10 years is provided. This allows companies to reinvest profits in business development without diverting resources to tax payments.

The solutions implemented by the COREDO team have already allowed several clients to obtain tax holidays for the entire investment cycle, which has significantly increased their competitiveness in the market.

Subsidies for technological equipment and scientific research

The state subsidizes up to 50% of the costs of acquiring technological equipment and also provides tax relief for companies investing in scientific research and innovation. To obtain such subsidies, preparation of a comprehensive business plan and undergoing an audit procedure are required.

Our experience at COREDO has shown: with proper document preparation and process support, the probability of subsidy approval exceeds 80%.

Preferential loans from the state fund: grants for future investments

Investors can use preferential loans for business development through the state fund Dotace pro investice do budoucna.

The amount and lending terms depend on the sector and investment volume, but in some cases the loan rate can be significantly below market. The COREDO team accompanied clients at all stages of obtaining such loans, from preparing the application to monitoring the targeted use of funds.

Taxation of income from investments

Illustration for the section «Taxation of income from investments» in the article «Investment companies of the Czech Republic - taxation and advantages for investors»
For effective tax planning, it is important to consider the specifics of taxation of different investment instruments.

Taxation of income from the sale of securities and unit certificates

Income from the sale of securities that have been held for more than three years is exempt from profit tax. Separate rules apply to unit certificates: income from them is taxed at a rate of 15%

, However, when reinvesting funds into Czech assets, tax deductions may be available. Solutions implemented by COREDO have allowed clients to structure transactions so as to maximize tax exemptions and minimize liabilities upon exit from investments.

Tax consequences of holding shares and stakes in companies

Holding stakes in Czech companies through a parent company structure (with a stake of at least 10% and a holding period of at least 12 months) allows taking advantage of the participation exemption. This allows not paying tax on dividends and capital gains when the stakes are later sold. This approach is widely used in international practice and has proven effective in COREDO’s cases.

Changes in Czech Tax Legislation 2025

Illustration for the section «Changes in Czech Tax Legislation 2025» in the article «Investment Companies of the Czech Republic - taxation and benefits for investors»
The 2025 developments require special attention in strategic investment planning.

Introduction of a minimum tax for large companies

From 2025, a minimum tax of 15% is introduced for companies with revenues exceeding EUR 750 million. This aligns with global trends and is aimed at combating aggressive tax planning.

For investment structures this means the need for a thorough assessment of the tax burden and a review of corporate strategies. COREDO’s experience shows that with the right choice of holding jurisdiction and the use of international agreements, it is possible to maintain a competitive tax rate even under the new rules.

Increase in social and health insurance contributions

In 2025 mandatory social and health insurance contributions increase, affecting overall business profitability.

For entrepreneurs using the simplified tax system, it is important to take the new contribution ranges into account and plan the budget considering these changes.

Updates to the simplified tax system

New tax brackets and fixed rates for small entrepreneurs are being introduced, which simplifies administration but requires regular monitoring of changes. COREDO’s solutions allow clients to adapt promptly to new requirements and avoid penalties for untimely fulfillment of tax obligations.

Registration of an investment company in the Czech Republic

Illustration for the section 'Registration of an investment company in the Czech Republic' in the article 'Investment companies in the Czech Republic - taxation and advantages for investors'
Company registration in the Czech Republic: is a strictly regulated process that requires attention to detail and compliance with all formal requirements.

Registration stages and required documents

The registration process includes several key stages:
  • Preparation of founding documents and selection of a unique company name.
  • Determination of the structure of shareholders and directors.
  • Submission of documents to the Commercial Register and tax authorities.
  • obtaining a license to carry out investment activities (if necessary).

The COREDO team supports clients at every stage, ensuring the correct preparation of documents and minimizing registration times.

Disclosure requirements for foreign investors

Since 2025, requirements for disclosure of information on beneficial owners and financial reporting have been tightened.

Foreign investors are required to provide an expanded set of documents confirming the source of funds and ownership structure. Our experience at COREDO shows: transparency and timely disclosure of information significantly reduce the risks of account freezes and claims from regulators.

Tax risk management and compliance

In today’s environment, effective management of tax risks has become an integral part of an investment strategy.

Data protection and GDPR compliance

Compliance with GDPR standards and personal data protection is a mandatory requirement for all companies working with EU residents.

COREDO’s solutions provide for the implementation of comprehensive data protection policies and regular audits of procedures, which minimizes the risk of fines and reputational damage.

Control of foreign tax rates and avoidance of double taxation

The Czech Republic has concluded more than 90 double taxation agreements, allowing taxes already paid abroad to be taken into account when calculating liabilities in the Czech Republic.

For investors, this is a key tool for tax optimization. COREDO’s practice shows that the proper application of international agreements can significantly reduce the overall tax burden and avoid double taxation on cross-border investments.

Practical steps for investors to reduce taxes

Moving from theory to practice, I will outline the key tools and solutions that enable investors to use the tax advantages of the Czech Republic as effectively as possible.

Using tax reliefs and incentives

Optimizing the tax burden begins with an analysis of all available reliefs: tax holidays, subsidies, accelerated VAT refunds, reduced rates for innovative projects.

The COREDO team has implemented projects where the overall tax burden was reduced by more than 30% through the effective use of these tools.

Application of the participation exemption regime

Structuring ownership through a parent company with a share of at least 10% and a holding period of at least 12 months allows dividends and capital gains to be fully exempt from taxation.

This approach is particularly effective for holding structures and investment funds operating with portfolios of Czech assets.

Accounting for foreign taxes and double taxation treaties

When planning international investments, it is important to take into account not only Czech but also foreign tax obligations. COREDO’s solutions provide for a comprehensive analysis of tax treaties and optimization of ownership structures to minimize the overall tax base.

Key takeaways for investors

  • The Czech Republic remains one of the most transparent and stable jurisdictions for investment business in the EU.
  • The corporate tax (21%) and the minimum tax regime (15% for large companies) require strategic planning, but with proper structuring and the use of incentives the effective tax burden can be significantly reduced.
  • Using investment passports, tax holidays, subsidies, and international agreements enables establishing an effective investment and tax strategy.
  • COREDO’s practice confirms: investment success in the Czech Republic depends on a comprehensive approach, from proper company registration to continuous monitoring of legislative changes and managing tax risks.

Comparison of taxes and incentives for investment companies in the Czech Republic, 2025

Tax/Incentive Rate/Conditions Notes
Corporate tax 21% For all companies
VAT 21% (reduced rates 10-15%) For socially significant goods
Dividend tax 15% Withheld at source
Minimum tax 15% For companies with turnover exceeding EUR 750 million
Corporate income tax exemption Up to 10 years For new investments
Equipment subsidies Up to 50% For technological equipment
Preferential loans According to the fund’s terms Grants for investments in the future

Conclusion

Investing in the Czech Republic: it is not just access to the EU market, but also an opportunity to build a business with an optimal tax structure, transparent rules of the game and access to government incentives. company registration in the Czech Republic and sound tax planning allow investors to implement long-term strategies, minimize risks and increase the profitability of projects. COREDO’s experience proves: success in the Czech Republic is achieved thanks to a comprehensive approach, expert support and continuous monitoring of changes in legislation.

A payment system license is an official authorizing document issued by a financial regulator (the central bank or a specialized authority) that confirms the right of a payment system operator or payment gateway to carry out licensed payment operations, hold and process clients’ funds, and issue electronic money. It is based on the regulatory framework of payment systems designed to ensure financial security, transparency of settlements, and protection of users’ interests.

In the practice of COREDO we have repeatedly encountered situations where entrepreneurs underestimated the regulatory function of the license, perceiving it as a formality. In reality, a license – is not only the legal basis for conducting activities, but also a key element of financial regulation that determines access to banking infrastructure, international payment systems (Visa, MasterCard, UnionPay), as well as to technology partners and investors.

Licensing: functions and benefits

Licensing of payment operations performs three strategic tasks:

  • Prevention of illegal circulation of financial resources: A license requires the implementation of a comprehensive AML/CTF policy, which minimizes the risks of money laundering and terrorist financing.
  • Stability of the settlement infrastructure: Regulatory requirements for authorized capital and the financial stability of the payment system operator ensure the reliability and uninterrupted operation of the payment gateway.
  • Competitive advantages: Having a payment system license significantly increases customer trust, allows cooperation with leading banks, integration with international payment services, and expansion of the business’s geographic reach.
The solution developed by COREDO for one of its European clients not only enabled the obtaining of an EMI license, but also the establishment of a partner network with leading EU banks, which became a catalyst for scaling the business into Southeast Asian markets.

License requirements for payment gateways

Illustration for the section «License requirements for payment gateways» in the article «Financial license for payment gateways»

Financial requirements and share capital

The key barrier to obtaining a payment system license is the financial requirements. In different jurisdictions the minimum share capital for a payment license varies significantly: in Estonia: from €350,000 for an EMI license, in the Czech Republic: from €125,000, in Cyprus – from €200,000. For a Payment Service Provider license (PSP) requirements may be lower, but the payment operator’s financial stability and the transparency of funding sources are always assessed.

COREDO’s practice confirms that regulators pay special attention not only to the amount of share capital, but also to its origin, ownership structure and financial forecasts. It is important to prepare in advance justification of the lawful origin of funds and a detailed business plan to obtain a payment license.

Organizational and personnel requirements

The company’s structure and the qualifications of the payment system’s managers: another critical aspect. Regulators require:

  • A transparent ownership and governance structure.
  • Qualified directors and managers with experience in financial services and payment operations.
  • The presence of a separate branch or virtual office in the licensing jurisdiction (for example, for Singapore: a mandatory local director and a registered legal address).
In one of COREDO’s cases for an Asian client we built an organizational structure taking into account residency and qualification requirements, which allowed the owners’ and managers’ integrity checks to be passed on the first attempt.

AML/KYC requirements and data protection

Modern regulation of payment systems is impossible without strict compliance with AML/CTF policies and the implementation of KYC procedures. The payment system operator must:

  • Develop and implement internal rules for combating money laundering.
  • Ensure client identification and verification (KYC).
  • Organize the protection of payment system users’ data in accordance with international standards (GDPR, PDPA, etc.).
  • Implement a system for monitoring suspicious transactions and managing fraud risks.
COREDO’s practical experience shows that inadequate handling of these aspects is the main reason for delays and license refusals.

Process of obtaining a payment system license

Illustration for the section «Process of obtaining a payment system license» in the article «Financial license for payment gateways»

Preparation of documents and business plan

The first stage is preparing the complete package of documents for registering a payment system. It includes:

  • Constituent documents, company charter, meeting minutes.
  • Financial statements and a business plan for obtaining the payment license.
  • Documents confirming the lawful origin of funds.
  • AML/CTF policies, internal KYC and data protection regulations.
  • Certificates confirming the integrity and reliability of owners and management.
COREDO’s experience shows that a well-prepared business plan with financial forecasts and a scaling strategy significantly speeds up the application review process.

Submission of the application and interaction with the regulator

The application is submitted to the authorized financial authority or the central bank of the relevant jurisdiction. Regulatory requirements for payment systems include:

  • Verification of the integrity and reliability of the payment system owners (Due Diligence).
  • Analysis of the company structure and management qualifications.
  • Assessment of AML/CTF policies’ compliance with international standards.
During the review process, the regulator may request additional documents, clarifications on the business model or capital structure. The COREDO team assists clients at every stage, including preparing responses to regulator requests and participating in interviews.

Timelines and stages of the application review

The timeline for obtaining a payment license depends on the jurisdiction and the complexity of the structure. On average:

  • Document preparation: 1–2 months.
  • Application review and integrity checks: 3–6 months.
  • Interaction with the regulator and audit of the payment system: up to 9 months.
In some cases (for example, when document legalization is required or with an international structure) timelines may increase. A solution developed by COREDO for one of its clients in Singapore reduced the licensing timeframe from 12 to 7 months due to careful preparation and proactive interaction with the regulator.

Licensing in the EU, Asia and Africa: specifics

Illustration for the section «Licensing in the EU, Asia and Africa: specifics» in the article «Financial license for payment gateways»

EMI license in Europe: requirements

In the EU the main form of licensing is the EMI license (Electronic Money Institution), which allows issuing electronic money, conducting payment transactions and integrating with SEPA, SWIFT, Visa, MasterCard. Main requirements:

  • Minimum share capital: from €350,000.
  • Compliance with payment activity regulations (PSD2, EMD2).
  • Strict AML requirements/KYC and personal data protection (GDPR).
The COREDO team carried out projects to obtain EMI licenses in Estonia and the Czech Republic, where special attention is given to financial stability and the transparency of the company’s structure.

Key differences between Asian and African markets

In Asia (for example, in Singapore) requirements for payment licenses are regulated by the Monetary Authority of Singapore (MAS). Key features:

  • Mandatory presence of a local director and a registered address.
  • Minimum share capital: from SGD 100,000 for a standard license.
  • Strict control over AML/CTF policies and cross-border payments.
In Africa, regulation is more fragmented, but the trend toward tightening requirements for financial security and data protection is clear. In COREDO’s practice we have encountered the need to adapt business models to local specifics, including currency control and data localization requirements.

Choosing a jurisdiction for registering a payment operator

jurisdiction choice – a strategic decision affecting cost, timelines and scaling potential. It is important to consider:

  • Financial and regulatory conditions (requirements for capital, structure, reporting).
  • The possibility of opening a virtual office for the payment license.
  • The reputation of the jurisdiction among international banks and partners.
COREDO’s experience shows that for startups and companies focused on international markets, optimal choices often are Cyprus, Estonia, the Czech Republic or Singapore due to the balance between requirements, licensing speed and access to payment infrastructure.

Licensed payment gateways: technological and operational aspects

Illustration for the section «Licensed payment gateways: technological and operational aspects» in the article «Financial license for payment gateways»

Integration and security of payment systems

A modern payment gateway is not just software but a comprehensive payment infrastructure integrated with banks, international payment networks and third-party services. Critical aspects:

  • API integration with banks and partners.
  • Protection of payment system users’ data using encryption and multi-layer authentication.
  • Cybersecurity of payment systems, a mandatory requirement for passing audits and meeting regulator requirements.
COREDO implements solutions that allow clients not only to comply with PCI DSS standards but also to ensure resilience to DDoS attacks and fraud attempts.

Choosing partners and infrastructure

The successful operation of a payment gateway is impossible without reliable technology partners and infrastructure providers. Key points:

  • Assess partners’ experience and reputation in the market.
  • Choose cloud payment solutions that provide scalability and fault tolerance.
  • Enter into transparent agreements with providers, taking into account the regulator’s requirements for data storage and processing.
In one of COREDO’s projects for a British client, integration with multiple providers was implemented, which made it possible to ensure uninterrupted operation of the payment system even during a sharp increase in load.

Technology compliance with regulatory requirements

The technological infrastructure must not only provide fast and convenient payments but also meet the requirements for risk management in payment systems:

  • Implementation of a system for monitoring suspicious transactions.
  • Regular vulnerability testing and security audit.
  • Compliance with payment operation regulations and cybersecurity standards.
COREDO’s experience shows that integrating compliance tools at the design stage of a payment gateway reduces the costs of subsequent adaptation and minimizes regulatory risks.

Risks and risk management when working with a payment license

Illustration for the section «Risks and management when working with a payment license» in the article «Financial license for payment gateways»

Key risks for payment operators

Payment system operators face three groups of risks:

  • Operational risks: service disruptions, technical errors, human factors.
  • financial risks: insufficient capital, losses due to fraud.
  • Reputational risks: data breaches, regulatory non-compliance.
The COREDO team helps clients build internal control and business continuity systems to minimize the impact of incidents.

AML/KYC compliance and data protection

To meet AML/CTF requirements and protect personal data, it is necessary to:

  • Continuously update internal policies and procedures.
  • Conduct regular training for staff.
  • Use automated KYC procedures and transaction monitoring systems.
In one of COREDO’s cases for the Asian market, we implemented an automated customer verification module, which reduced the rate of false positives and sped up the onboarding process.

Monitoring and auditing of the payment system

Effective compliance monitoring includes:

  • Conducting regular audits of the payment system.
  • Monitoring changes in regulatory acts and adapting internal procedures.
  • Planning crisis management and recovery after failures.
The solution implemented by COREDO for one of its clients in the EU not only allowed them to pass an external audit without remarks, but also increased trust from partner banks.

Practical recommendations for entrepreneurs

How to prepare for licensing

  • Assemble a team with relevant experience and qualifications.
  • Prepare a complete set of documents, including a business plan, AML/KYC policies, and proof of funding sources.
  • Conduct preliminary due diligence on owners and executives.

How to choose a jurisdiction and a partner

  • Assess capital requirements, company structure, and reporting obligations across different countries.
  • Consider opening a virtual office for the payment license.
  • Choose technology partners with experience integrating payment systems and complying with security standards.

How to minimize risks and pursue long-term development

  • Implement a risk management system in payment systems with regular audits and monitoring.
  • Plan the scaling of the payment system with the requirements of new markets in mind.
  • Invest in team training and updating compliance procedures for the long-term development of the payment system.

Conclusions and next steps

  • Prepare a complete package of documents and a business plan in line with regulator requirements.
  • Choose an appropriate jurisdiction, taking into account financial and regulatory conditions.
  • Ensure AML compliance/KYC and protection of user data.
  • Take care when selecting technology partners and infrastructure.
  • Plan risk management and audits for sustainable business development.
Licensing stage Main requirements Timeframe (approx.) Key documents
Document preparation Articles of association, business plan, financial reports 1-2 months Articles of association, minutes, financial documents
Application submission and review Due diligence checks, AML/KYC 3-6 months Application, AML/KYC documents
Interaction with the regulator Responses to inquiries, payment system audit Up to 9 months Additional documents, audit reports
obtaining the license Official authorization, registration After successful completion License, authorization documents

If you want to go through the payment system licensing process without unnecessary risks and delays, the COREDO team is ready to become your strategic partner at every step: from choosing a jurisdiction to building a scalable payment infrastructure.

ZISIF §15 is a special regime provided for by the Czech Investment Funds Act (240/2013 Sb.) that allows the creation of alternative investment funds (AIF) with a unique combination of flexibility and regulatory transparency. Unlike traditional funds, ZISIF §15 makes it possible to shape the fund’s corporate structure to the needs of a specific investor, whether a family office, a holding, or a venture platform.
A feature of ZISIF §15 is that it does not require obtaining a full AIFM manager license if the fund serves a limited circle of investors and does not carry out public capital raising. This significantly simplifies the launch of an investment company in the Czech Republic, reduces compliance costs, and speeds up the fund’s integration into international holding structures.
Implemented projects show: ZISIF §15 is becoming the optimal tool for structuring international investments, especially in cases where a balance is required between asset protection, tax optimization, and compliance with European transparency standards.

Corporate Structure and Asset Management

Illustration for the section 'Corporate Structure and Asset Management' in the article 'How to use ZISIF §15 for international investments'

The key to a fund’s efficiency under ZISIF §15 – a properly structured corporate structure. In practice, two main forms are used: s.r.o. (limited liability company), optimal for family offices and small investment groups, and joint-stock company (a.s.), suitable for large projects with a diversified asset portfolio and the involvement of institutional investors.
Asset management is built on the principles of fiduciary responsibility: appointment of a professional director or management company, clear separation of control and decision-making functions, regular investment reporting. In each case, individual management mechanisms are developed, taking into account AML compliance requirements for funds and international standards of investment transparency.
Important aspect – maintaining investment reporting. Automation of reporting processes and integration of digital solutions in fund management not only reduce operational risks but also increase trust from investors and banks.

Structuring international investments through ZISIF §15

Illustration for the section «Structuring international investments through ZISIF §15» in the article «How to use ZISIF §15 for international investments»

ZISIF §15 opens broad opportunities for tax optimization of investments and asset protection through a fund. Thanks to the features of Czech legislation and double taxation avoidance agreements, such funds can be easily integrated into international holding structures, providing flexibility and transparency for beneficiaries.
The solutions allow for taking into account CFC rules (controlled foreign companies), features of beneficial ownership and disclosure requirements. This is critically important for investors from the EU, Asia and the CIS who face tightening tax and financial controls in their jurisdictions.
ZISIF §15 is also effective for diversifying an investment portfolio: through the fund one can invest in a wide range of assets. This approach includes traditional financial instruments (stocks, bonds, derivatives), real estate and infrastructure projects, startups and venture investments, cryptocurrencies and digital assets (provided AML compliance is observed), as well as structuring family and corporate capital.

ZISIF Section 15 for family offices and investors

Illustration for the section 'ZISIF §15 for family offices and investors' in the article 'How to use ZISIF §15 for international investments'

ZISIF §15 is a unique tool for family offices focused on protecting family wealth and managing legacy. Unlike traditional trust structures, a Czech investment fund allows integration of family and corporate capital, providing flexibility in management and transparency for future generations.
Using ZISIF §15 to manage legacy and diversify assets not only reduces the tax burden but also ensures continuity in investment management. The fund can invest in real estate, venture projects, infrastructure, digital and biotech assets, which is especially important for families with a global presence.
For institutional investors and corporations, ZISIF §15 becomes a platform for implementing complex investment strategies: integrating the fund into a holding, risk management, and using international financial instruments. This approach provides scalability of the fund structure with the possibility of attracting new investors (up to 20 non-qualified or an unlimited number of qualified), as well as simplicity of corporate governance, whereby founders can use an s.r.o. or a joint-stock company while retaining control over the fund and profit distribution.

Legal and compliance risks when using ZISIF

Illustration for the section «Legal and compliance risks when using ZISIF» in the article «How to use ZISIF §15 for international investments»

Failure to comply with laws and AML compliance requirements when working with funds under ZISIF §15 can lead to serious legal and financial risks: from fines and account freezes to the loss of an investment license. That is why special attention is paid to legal support for projects and the implementation of effective internal control systems.
Key recommendations for investors include conducting regular checks of beneficial ownership and compliance with CFC rules, automating investment reporting and transaction monitoring processes, using digital solutions for risk management and ensuring transparency of operations. Only a comprehensive approach to legal support, integration of AML compliance and continuous monitoring of regulatory changes can minimize risks and ensure the fund’s long-term sustainability.

Practical steps for creating and managing ZISIF §15

Illustration for the section 'Practical steps for creating and managing ZISIF §15' in the article 'How to use ZISIF §15 for international investments'

Document preparation begins with developing the fund’s investment strategy and defining the corporate structure. It is necessary to prepare the founding documents, including the articles of association, internal regulations, and agreements between the founders. The ownership structure and allocation of shares must be defined taking into account requirements for beneficial ownership and fiduciary management. A detailed business plan for the investment fund is also required, describing the investment strategy, target assets, and return scenarios for PRIIPs, as well as a list of founders and beneficiaries with verification of sources of funds.
Fund registration involves submitting documents to the competent authorities, appointing a director and, if necessary, an asset management company in the Czech Republic, and opening a corporate account in a Czech or European bank.
Management organization includes implementing AML compliance procedures and ensuring process transparency with regular reporting to investors.
Integrating the fund into a holding involves structuring ownership and integrating with international financial instruments taking tax treaties into account.
Control and reporting include automation of investment reporting, regular audits, and providing transparent information to investors and regulators.

Main findings and recommendations

The use of ZISIF §15 for international investments is a strategic tool for asset management, tax optimization and capital protection on a global scale. A properly structured ZISIF §15 fund enables the pooling of family and corporate capital, the implementation of complex investment strategies, and the provision of transparency for investors and regulators.
It is recommended that entrepreneurs and investors from Europe, Asia and the CIS consider ZISIF §15 as part of a comprehensive approach to international investments. It is important to ensure professional legal support, the integration of AML compliance and continuous monitoring of regulatory changes at all stages – from fund design to its integration into global investment strategies.

Comparative table of investments under ZISIF §15

Investment type Advantages through ZISIF §15 Management and taxation features
Real estate Asset protection, tax optimization Requirement for valuation and reporting
Startups and venture projects Diversification, access to innovation High risks, long-term strategies
Infrastructure projects Stable income, government support Complex legal procedures
Crypto assets and digital assets Flexibility, new markets Special AML and regulatory requirements
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