ETF základy
Can I Buy US ETFs from the Czech Republic? Legal Routes and Real Solutions
Key takeaways
- Retail investors in the EU have been unable to buy US ETFs (SPY, QQQ, VTI) through standard brokers since 2018, because these ETFs do not have a KID document as required by the PRIIPs regulation.
- Professional investors (opt-up, minimum €500,000) have access to US ETFs — but for the average Czech investor this is not a viable route.
- The best practical solution is to buy a European UCITS equivalent: iShares Core S&P 500 UCITS ETF (IE) instead of SPY, Vanguard FTSE All-World UCITS instead of VTI.
- UCITS versions have Irish domicile with 15% withholding tax on US dividends — in practice comparable to what a US investor in Ireland would pay.
- Direct purchases through US platforms (Schwab, Fidelity) are technically complicated for Czech tax residents and tax-inefficient.
Retail investors residing in the EU have been unable to buy US ETFs such as SPY, QQQ, or VTI through standard European brokers since 1 January 2018 — due to the PRIIPs regulation, which requires a standardised KID document that US ETFs do not provide.
Why it does not work: the PRIIPs regulation
EU Regulation No. 1286/2014 (PRIIPs), in force since January 2018, requires that every packaged investment product offered to retail investors in the EU must have a KID (Key Information Document) in the local language. US ETFs such as the SPDR S&P 500 ETF Trust (SPY) do not have a KID and do not issue one for the EU retail market. The result: a broker in the EU (Fio, LYNX, eToro, Trading 212) will simply reject your order for a US ETF.
What professional investors are and why most people do not pursue that route
Investors classified as "professional" under MiFID II are not subject to the KID requirement. Professional status can be obtained through an opt-up application, but brokers typically require: a portfolio of €500,000 or experience in the financial sector. For the vast majority of Czech investors, this is an unrealistic requirement.
The real solution: UCITS equivalents
The good news is that all the key US indices have their European UCITS counterparts with Irish domicile:
- Instead of SPY/IVV: iShares Core S&P 500 UCITS ETF, Vanguard S&P 500 UCITS ETF — both with "IE" ISIN.
- Instead of VTI/ITOT: Vanguard FTSE All-World UCITS ETF or iShares Core MSCI World UCITS ETF.
- Instead of QQQ: iShares Nasdaq 100 UCITS ETF.
These funds track practically identical indices and, thanks to their Irish domicile, pay 15% withholding tax on US dividends — just like their US counterparts. A comparison of the All-World vs. S&P 500 approach is available in the article All-World vs. S&P 500.
Alternatives outside the mainstream
Some platforms claim to allow the purchase of US ETFs through CFDs or other derivatives — that is fundamentally a different product with a different risk profile. It is not the same as owning the underlying ETF. For a core portfolio, we recommend sticking to the UCITS approach and reviewing the broker guide for Czech investors in the article how to choose a broker in the Czech Republic.
FAQ
Why can I not buy SPY or QQQ in the Czech Republic?
EU PRIIPs regulation (2018) requires every investment product for retail investors in the EU to have a KID document. US ETFs do not have a KID, which is why standard European brokers do not offer them to retail clients.
Is there a legal route to US ETFs for Czech investors?
Theoretically through professional investor status (MiFID II opt-up, typically a €500,000 portfolio). In practice, however, the better route is to buy a UCITS equivalent — iShares or Vanguard UCITS ETFs tracking the same indices, with Irish domicile and 15% withholding tax.
Is a UCITS ETF on the S&P 500 as good as US SPY?
For a long-term investor, practically yes. It tracks the same index, the TER is comparable, and Irish domicile ensures 15% withholding tax on US dividends — the same as SPY for US investors.