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The government has approved a draft amendment to the VAT Act introducing a series of measures aimed at detecting tax fraud and increasing transparency within the VAT system. This is a major reform that will affect several areas – from taxpayer registration to new rules for claiming input tax deductions.
The legislative package also includes changes related to electronic invoicing, which you can read about in our separate article.
The amendment is currently awaiting parliamentary approval, with most of the measures expected to take effect from 1 January 2026.
The amendment introduces a new concept – registration of a VAT group by the tax authority ex officio. The aim is to prevent tax evasion through entities that are formally independent but economically interconnected.
Under the new rules, the tax authority will have the power to register two or more entities as a single VAT group. On the date of registration:
The representative of the group will be obliged to report any changes in registration. Failure to do so may result in a penalty of up to EUR 10,000.
If a person registered for a special VAT scheme in another EU Member State becomes a member of such a group, their individual VAT number with the suffix “EX” will be withdrawn.
From 2027, the amendment extends the option of voluntary registration under Section 7a for taxable persons who do not meet the conditions for mandatory VAT registration.
However, newly registered entities will be required to ensure technical readiness to receive electronic invoices – linking them to the e-invoicing system gradually being implemented across Slovakia.
The tax authority will have the power to require the customer to pay the VAT amount from an invoice directly to the tax authority’s account, instead of to the supplier, in cases where there is a reasonable suspicion that the supplier will not remit the tax.
If the customer fails to comply with this obligation or pays only part of the VAT, they may face a penalty up to the amount of VAT stated on the invoice.
From 1 July 2030, a new substantive condition will apply for VAT deduction. The right to deduct input VAT on domestic supplies of goods or services subject to the reporting obligation will only arise if the taxpayer possesses an electronic invoice.
If the invoice is not issued in electronic form, the right to deduct VAT will not apply.
If the tax authority issues a preliminary measure due to concerns that the tax will not be paid or will be uncollectible, the deadline for refunding an excessive VAT deduction will be suspended.
The period will resume only once the preliminary measure is revoked.
This measure aims to prevent VAT refunds in cases where there is a risk of tax evasion.
The amendment also modifies the Tax Code, expanding the powers of tax authorities in enforcing tax arrears.
A tax administrator who is not locally competent for a particular taxpayer will newly be allowed to establish a lien or carry out tax enforcement proceedings.
An exception applies to tax administrators that are municipalities
The VAT amendment introduces fundamental changes in how businesses will be registered, monitored, and held accountable for VAT compliance.
The introduction of group registration, new payment mechanisms, and mandatory e-invoicing will have a significant impact on companies’ financial and accounting processes.
If you believe that some of these changes may affect your company, please contact our experts. We will help you assess the impact of the amendment and prepare for the new obligations in time.
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