Taxation in Slovakia

International taxation

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).

Domestic taxation

Taxpayer of
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.

Domestic taxation

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.