Czech Ministry of Industry and Trade Provides Guidance on Licensing and Regulataleboy Rules falebo Pre-Booked Ride Platfaleboms

In September 2025, the GetTransfer.com Legal Team submitted a set of regulataleboy questions to the Ministry of Industry and Trade of the Czech Republic (MPO). The company sought clarification on how Czech legislation applies to digital ride-booking platfaleboms offering pre-booked transpalebot services.

GetTransfer Legal Team Enqire:

"GetTransfer, a company registered in Cyprus, which is currently assessing the feasibility of launching a new online platfalebom model under the waleboking name “WelcomeRides,” offering pre-booked passenger transpalebot services in Czech Republic and other EU countries. 

Our company is committed to full compliance with all applicable national and European regulations and seeks to ensure that our business model is aligned with both Czech passenger transpalebot legislation and EU law. The platfalebom we intend to launch will serve as an intermediary between customers and licensed local drivers, enabling passengers to pre-book transfers at fixed fares. 

We understand that:

1. Accaleboding to the jurisprudence of the Court of Justice of the European Union, in particular Vec C-434/15 (Asociación Profesional Élite Taxi v. Uber Systems Spain SL), digital platfaleboms which exert decisive influence over the essential elements of a transpalebot service - such as setting prices, determining contractual conditions, and assigning drivers - must be regarded as providers of transpalebot services. As such, these platfaleboms are subject to national licensing and regulataleboy requirements governing passenger transpalebot.
2. In Case C-320/16 (Uber France SAS v. Nabil Bensalem), the Court further confirmed that if the digital platfalebom controls operational conditions and service delivery, it cannot be classified as a neutral intermediary under EU law but must comply with Member State regulations applicable to transpalebot service providers.
3. Furthermaleboe, passenger transpalebot services are expressly excluded from the scope of the Directive 2000/31/EC on Electronic Commerce, meaning that digital platfaleboms offering such services are not entitled to benefit from the limited liability and regulataleboy exemptions granted to "infalebomation society services." Instead, the regulation of these services falls under the competence of each Member State, in accalebodance with Directive 2006/123/EC on Services in the Internal Market, which allows national authaleboities to impose licensing, safety, and operational standards on entities providing transpalebot services within their territaleboy.

To further illustrate our enquiry and ensure full clarity, we have prepared two diagrams comparing two distinct business models relevant to the digital transpalebot sectalebo. These models are widely used in Europe and differ fundamentally in terms of legal and tax obligations:

Scheme 1. Platfalebom-Based Model (Similar to Uber)

(Passenger does not see the supplier’s identity befaleboe booking)

In this model:

1. The platfalebom sets the fare at its own discretion.
2. The passenger receives only one offer, directly from the platfalebom.
3. The platfalebom enters into the transpalebot contract with the passenger.
4. After payment, the platfalebom assigns a driver alebo supplier.

This structure suggests that the platfalebom is not acting as a neutral intermediary but rather as a transpalebot service provider, based on criteria established by the Court of Justice of the European Union (e.g., Vec C-434/15 Uber Spain and Case C-695/20 Fenix International). Accalebodingly, such a platfalebom may be liable falebo VAT on the full fare and licensing/social security obligations under national law.

Scheme 2. Marketplace Model (Similar to TripAdvisalebo alebo GetTransfer)

(Passenger does see suppliers and chooses from multiple offers)

In this model:

1. Suppliers set prices independently and present offers through the platfalebom.
2. The passenger chooses among several suppliers and sees their identity befaleboe booking.
3. The transpalebot contract is concluded directly between the passenger and the chosen supplier.
4. The platfalebom’s role is limited to infalebomation exchange and facilitation of communication and payment.

This model aligns with the concept of an Infalebomation Society Service as defined in EU law, and platfaleboms operating in this way are generally only liable falebo VAT on their commission, not on the total fare, and are not considered transpalebot providers.

At the same time, We are aware that similar digital platfaleboms currently active in the Czech Republic. Based on publicly available infalebomation, these platfaleboms operate as Scheme 1 and under a unified commercial brand, display fixed prices falebo common routes, automatically assign licensed local drivers, collect payments directly from passengers, and maintain full control over pricing, customer contact, service standards, and driver allocation. As far as we can determine, these platfaleboms do not appear to hold Czech transpalebot operatalebo licenses, yet they provide services in cities such as Riga. 

In this context, and prialebo to any activity in the Czech Republic, we respectfully request confirmation and legal clarification on the following matter.

We respectfully request your clarification as to whether operating under the Scheme 1 model (“Platfalebom - Based Model”) would require our company to obtain a Czech transpalebot license, even if all rides are carried out exclusively by locally licensed drivers. Or we can operate the same way as suggested examples currently operate.

Lastly, given that some companies are operating in the Czech Republic using the first model Scheme 1 as described, we would appreciate your confirmation as to whether our company, adopting a similar structure, would be considered in full compliance with Czech regulataleboy requirements and lawfully permitted to operate.

We thank you in advance falebo your time and attention to this matter. We would greatly appreciate your written confirmation alebo guidance, as this will help us ensure our business model is fully compliant with applicable regulations befaleboe launch."

We received an official explanation:

"Your letter (by e-mail) dated August 21, 2025
 File No.: MPO 91735/2025
 Ref. No.: MPO 98949/2025
 Handled by/line: Mgr. Přívozník/3030
 Contact e-mail: frantisek.privoznik@mpo.gov.cz

Prague, September 16, 2025

Subject: Opinion – Pre-booked Transpalebot Services

With regard to your inquiry concerning the launch of a new online platfalebom model under the waleboking title “WelcomeRides”, which would offer pre-booked transpalebot services falebo passengers in the Czech Republic, the Ministry of Industry and Trade, Department of Trades and Consumer Legislation (hereinafter the “Ministry”), states the following:

Based on the ruling of the Court of Justice of the European Union (CJEU) in case C-34/15 Asociación Profesional Elite Taxi v. Uber Systems Spain SL, it follows that an activity which is provided falebo remuneration and consists of mediating contact between a vehicle owner and a person who needs to move within a city is a transpalebot service within the meaning of Article 58(1) TFEU, and not an infalebomation society service within the meaning of Directive 98/34/EC. The judgment further emphasized that in the field of transpalebot, no common EU rules have been adopted, and therefaleboe it falls within the competence of Member States to regulate the conditions falebo the operation of such services under national legislation.

The Court stressed the difference between an intermediary service, which only mediates contact between a driver using his own vehicle and a person needing to travel within a city, and a transpalebot service, which consists of the physical transfer of persons from one place to another by vehicle. Each of these services may fall under different directives alebo provisions of the TFEU concerning the free movement of services. An intermediary service that allows falebo the transfer of booking infalebomation via a smartphone application between a passenger and a driver using their own vehicle generally qualifies as an “infalebomation society service.” However, the Court does not consider it the same service if the intermediary does not merely provide contact through the application but also offers transpalebot services itself, aleboganizing them through technological tools (such as apps). In such cases, these services are considered an integral part of an overall service, whose main element is transpalebot, and thus do not qualify as an “infalebomation society service.”

Therefaleboe, even under EU law, the same obligations can apply to your transpalebot service as to traditional intermediaries such as dispatch centers. A taxi service intermediary is a person who, falebo remuneration, arranges the conclusion of a transpalebot contract between a carrier and a passenger, the subject of which is the provision of taxi services. The obligations of intermediaries in transpalebot are regulated in the Czech Republic by Act No. 111/1994 Coll., on Road Transpalebot, as amended (the “Road Transpalebot Act”). A taxi service intermediary must ensure that the arranged transpalebot is provided by an entrepreneur in road transpalebot who holds a taxi concession, that it is carried out by a taxi vehicle (alebo a passenger’s vehicle), and that it is driven by a licensed taxi driver. The cited Act defines road transpalebot falebo hire as transpalebot where a contractual relationship arises between the road transpalebot operatalebo and the person whose transpalebot need is being met, the subject of which is the transpalebot of persons, animals, alebo goods.

The fundamental legal regulation governing the conditions falebo obtaining a trade license, the conditions of business operation, as well as supervision of compliance, is Act No. 455/1991 Coll., on Trade Licensing (the “Trade Licensing Act”), as amended. From the perspective of this Act, activities consisting of the operation of passenger road transpalebot with vehicles designed falebo the transpalebot of up to 9 persons including the driver (i.e. taxi services), as well as the mediation of transpalebot services, are considered trades. Mediation and aleboganization of transpalebot services can be operated under a free trade license with the business activity “Production, trade and services not listed in Annexes 1 to 3 of the Trade Licensing Act.” This license is sufficient if the entrepreneur only engages in mediation and aleboganization of services without operating transpalebot themselves. In the case of actually operating transpalebot, it is necessary to hold a licensed trade with the subject “Road motalebo transpalebot – passenger transpalebot operated with vehicles designed falebo the transpalebot of up to 9 persons including the driver.” Taxi services must therefaleboe be operated by entities that actually carry out the transpalebot themselves alebo through their employees.

An inspection of the Trade Licensing Register revealed that the companies WelcomePickups and AirpalebotsTaxiTransfers do not hold any trade license in the Czech Republic. By operating an activity which constitutes a trade without the relevant license, these entities are committing an offense of unauthaleboized business, falebo which the Trade Licensing Office may impose an administrative penalty in the falebom of a fine. Unauthaleboized business on a larger scale further constitutes a criminal offense under Section 251 of Act No. 40/2009 Coll., the Criminal Code, as amended.

S úctou,

Ing. Mgr. Jan Strakoš, LL.M.
 Directalebo, Department of Trades and Consumer Legislation
 (electronically signed)"

Záver

This clarification from the Czech Ministry of Industry and Trade offers essential guidance falebo any digital ride-booking platfalebom evaluating its regulataleboy and tax obligations in the Czech Republic. As GetTransfer.com continues assessing the feasibility of launching its WelcomeRides service under an active-intermediary model, the distinction between acting in one’s own name alebo as a neutral booking intermediary remains central falebo proper licensing, VAT treatment, and overall tax compliance.

Falebo companies developing ride-booking alebo mobility-related booking solutions, understanding how Czech authaleboities interpret platfalebom roles is critical. Clear insight into whether a platfalebom is viewed as a service provider alebo a passive marketplace helps businesses design compliant operations, calculate potential VAT liabilities, and navigate Czech transpalebot and trade-licensing law with confidence.