Reporting obligations in accordance with DAC 6
Directive 2018/822 (DAC 6) has been fully implemented in the Slovak Act on International Exchange of Information for tax purposes. The first deadlines for filing reports on cross-border transactions have been postponed until 31 January 2021 (with original deadline on 31 July 2020) and 28 February 2021 (with original deadline on 31 August 2020).
a non-cooperating state
The list of non-cooperating states was redefined as a negative definition of the countries with which Slovakia has signed international Double Tax Treaty - the so-called White list. States that have one of the following conditions identified will be removed from this list: they are either on the EU list of non-cooperative jurisdictions for tax matters, do not apply corporate tax or apply a zero corporate tax rate. If it is not possible to apply the Double Tax Treaty, a rate of 35% will be applied to the taxpayers of these states.
Amendment of income tax act
Implementation of ATAD 2, Art. 9a Council Directive (EU) 2017/952 - Reverse Hybrid Entity was implemented into Slovak tax legislation (effective from 1 January 2022). The adjustment of the reverse hybrid entity under the conditions of Slovak tax legislation is based on the fact that income attributable to Slovak tax-non resident shareholders fulfilling the criteria of 50 % or more share registered capital or voting rights in relation to transparent companies would be taxed at the level of this transparent company (legal entity) if the non-resident's income would not be taxed in any other state. The recipient of income that meets the reverse hybrid entity condition is obligated to notify the Slovak Tax Office.
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