Obligation to file a tax return for the Top-Up tax: Reminder
Based on the approved law by the National Council of the Slovak Republic on the top-up tax to ensure a minimum level of taxation of multinational enterprise groups and large domestic groups, and on the amendment of Act No. 563/2009 Coll. on Tax Administration (the Tax Code), as amended, all entities subjected to the top-up tax are required to file a notification, or a tax return (including payment of the tax), by 30 June 2026. We discussed these new obligations in more detail in our article on the Top-Up tax.
The good news for taxpayers is that if multiple entities of the same group operate within the territory of the Slovak Republic, they may agree that only one entity will file the notification containing the data necessary to determine the top-up tax. Provided that the relevant statutory conditions are met, the obligation to file the notification may also be fulfilled by the ultimate parent entity. However, each company of the affected group operating in the Slovak Republic is required to file its own top-up tax return. The top-up tax applies to the financial result achieved in 2024, with the minimum effective tax rate set at 15%.
For more information, please contact our Tax department.
