The Financial Transaction Tax in Slovakia (FTT) is one of the newest components of the Slovak tax system, yet it is evolving very dynamically. Since its introduction in 2024, four amendments have already been approved – the latest of which comes into effect on 1 January 2026. Below is an overview of the most important changes it introduces.

Definition of Recharged Costs

One of the major shortcomings of the previous wording of the Act was the insufficient definition of the term recharged expense. The amendment now clarifies this concept. A recharged expense should be understood as the amount of a financial transaction performed on behalf of a taxpayer by another person. In the case of a taxpayer with limited tax liability, this financial transaction must be related to that taxpayer’s activities carried out within Slovakia.

Indroduction of an Additional Permanent Establishment into the Tax System

As the legislator does not intend to waive the taxation of foreign entities under this tax, the amendment introduces a new type of permanent establishment, inspired by the legislation governing income tax and insurance tax. This concept is significant because legal entities without a registered seat in Slovakia will be considered taxpayers if they carry out activities in Slovakia through a permanent establishment.

For the purposes of the Financial Transaction Tax, a permanent establishment means:

• A fixed place of business in Slovakia if the activity exceeds 15 days during a calendar month,
• Online marketplaces or platforms and the sale of goods or services via an app or website with a Slovak domain (.sk) or hosted on servers located in Slovakia,
• Construction sites and places where construction or assembly projects are carried out for more than 15 days during a calendar month,
• The provision of services by a foreign person or persons working on its behalf for more than 15 days during a calendar month,
• A dependent agent who repeatedly negotiates or intermediates the conclusion of contracts on behalf of a foreign person,
• An insured risk located in Slovakia — such as insured real estate or insured vehicles registered in the relevant Slovak registry,
• A branch registered in the Commercial Register.

Adjustment of the Definition of Taxpayer and Income Payer

From 1 January 2026, only legal entities will be considered taxpayers, meaning that the Financial Transaction Tax will no longer apply to self-employed individuals.

For legal entities, this includes those that either perform financial transactions themselves or have such transactions carried out on their behalf. At the same time, a territorial principle is being introduced for this tax. Taxpayers will be classified as:

• Taxpayers with unlimited tax liability – those with a registered seat in Slovakia, or
• Taxpayers with limited tax liability – those without a registered seat in Slovakia, but who maintain a bank account or permanent establishment in Slovakia.

Certain entities are also explicitly excluded from the scope of taxpayers. These now include the public research institutions of the Slovak academy of Sciences (SAV), the Audit Oversight Authority, the Nation’s Memory Institute, the Office of the Commissioner for Persons with Disabilities, and the Office of the Commissioner for Children.

A taxpayer who performs a financial transaction (that is not excluded from taxation) on a special account intended solely for transactions exempt from the tax will also be considered a income payer.

Correspondingly, a new penalty has been explicitly introduced. If this special account is used for non-exempt payments, a fine ranging from €30 to €3,000 may be imposed.

If you believe that your company may become subject to the Financial Transaction Tax in Slovakia from 2026, and would like to obtain more information, our tax professionals will be happy to provide expert advice in this area.

Barbora Juhásová

Tax Manager | Accace Slovakia

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