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Disclaimer

This salary calculator has been prepared for general guidance and has been set only for simulation of net income calculation, therefore Accace does not take any responsibility and is not liable for any potential risks or damages caused by taking actions based on the information provided herein.

If you require more specific information related to payroll, income tax or labour law do not hesitate to contact our consultants in Slovakia.

Slovak or foreign investors entering the Slovak market may choose between several corporate forms. The fundamental law that regulates company formation in Slovakia is the Slovak Commercial Code. The Commercial Code regulates the corporate forms and business (entrepreneurial) activities that are defined as systematic activities conducted independently by an entrepreneur (either an individual or legal entity), in their own name and under their own responsibility for the purpose of making a profit.

Foreign persons may conduct entrepreneurial activity in the territory of the Slovak Republic under the same conditions and to the same extent as Slovak persons, unless stipulated otherwise by law. A foreign natural or legal person may establish any form of company either together with other foreign or Slovak persons or alone as a sole shareholder. In this respect, foreign natural and legal persons enjoy the same rights and bear the same responsibilities as Slovak persons and may not be discriminated against.

Download our 2024 guide on company formation in Slovakia, or read more below

Legal forms of business, minimum capital, contribution

Corporate forms introduced by the Slovak Commercial Code are:

General Partnership

Slovak: “verejná obchodná spoločnosť” or the abbreviation “v. o. s.” or “ver. obch. spol.”

A General Partnership is a company in which at least two persons carry out business activities under a common business name and bear joint and several liabilities for the obligations of the partnership with their entire property. There is no requirement of a minimum registered capital.

Limited Partnership

Slovak: “komanditná spoločnosť” or the abbreviation “k. s.” or “kom. spol.”

A company in which one or more partners are liable for the partnership’s liabilities up to the amount of their unpaid contributions (limited partners), and one or more partners are liable for the partnership’s liabilities with their entire property (general partners). The minimum contribution of the limited partner is in the amount of EUR 250.

Limited Liability Company

Slovak: “spoločnosť s ručením obmedzeným” or the abbreviation “spol. s r.o.” or “s.r.o.”

This is the most common form of doing business in Slovakia. The company exists independently of its members and it may be established either by one person, a natural or legal person (with statutory restrictions described hereunder), or by two or more persons (up to 50).

According to the Commercial Code, minimum registered capital of EUR 5,000 is required. The minimum contribution of each shareholder is in the amount of EUR 750. The Commercial Code also requires that at least 30% from each contribution of the shareholder, but altogether at least 50% of the minimum registered capital stipulated by the Commercial Code shall be paid before the application for the registration of the company is filed with the Commercial Register.

A Limited Liability Company is liable for the breach of its obligations with all its assets, while shareholders guarantee for the breach of the obligations of the Limited Liability Company only up to their committed but unpaid contributions to the registered capital registered with the Commercial Register.

Simplified method of establishment of an LLC company

As of February 1, 2023, the shareholders may establish a limited liability company in addition to the standard method of incorporation also by using a simplified method, which consists in filling in a special electronic form for the drafting of the memorandum of association.

The simplification also consists in the elimination of one of the steps prior to the registration of company in the Commercial Register, which is the obligation to apply to the Trade Licensing Authority for a trade licence. On the other hand, it is important to mention that the registered court shall be obliged to verify the integrity of the executive director. The regime for verifying the integrity of executive director is set more strictly for the incorporation of a company established by simplified method compared to the regime set in the Trade Licensing Act, as in this case absolute integrity is required, i.e. an executive director cannot be legally convicted of any criminal offence or have his/her convictions expunged.

Due to the fact that this is a simplified method of incorporation, the law stipulates certain limitations, resp. conditions according to which it is possible to use this method of incorporation over the standard method.

These conditions especially relate to:

  • the maximum number of shareholders, which is five;
  • the fact that the company can only be established for business purposes;
  • limit the shareholders to decide about the type and number of business activities of company;
  • stipulate executive director as the administrator of the contributions and prohibit the creation of a supervisory body.

With this method of incorporation, the shareholders are largely bound by the pre-prepared wording of the memorandum of association within the electronic form, from which they cannot deviate.

Joint-Stock Company

Slovak: “akciová spoločnosť” or the abbreviation “a. s.” or “akc. spol.”

The company may be established by a sole founder (provided that the founder is a legal entity) or by two or more founders. A Joint-Stock Company may be formed by a private agreement to subscribe for all shares, or by a public call for the subscription of shares.

The minimum registered capital is of EUR 25,000.

Simple Joint-Stock Company

Slovak: “jednoduchá spoločnosť na akcie” or the abbreviation “j.s.a.”

The Simple Joint-Stock Company is a new corporate form, introduced in Slovakia in 2017. It represents a lean version of Joint-Stock Company with minimum registered capital of EUR 1 and minimum nominal share value of Cent 1.

Simple Joint-Stock Company can provide greater flexibility comparing to Limited Liability Company or Joint-Stock Company in relation to unlimited number of shareholders (although the Simple Joint-Stock Company cannot be formed by public call for subscription of shares), minimum registered capital, or the possibility to issue several different types of shares with different rights of shareholders (e.g. more voting rights or greater profit share).

However, it is presumed that this form of company should cease to exist within following years and be replaced by LLC.

Co-operative

Slovak: “družstvo”

The purpose of a Co-operative is to undertake business activities or to ensure the economic and social or other benefits of its members.

The Co-operative bears liability for obligations of the Co-operative with its entire property, however the members do not bear liability for the obligations of the Co-operative.

Minimum registered capital of EUR 1,250 is required. The Co-operative can be established by minimum of 5 natural persons or 2 legal persons.

The Co-operative can provide certain level of anonymity to its owners (members) comparing to the other corporate forms, as the owners (members) are not registered within the Commercial Register, only listed internally within the Co-operative.

Enterprise or Organizational Branch of a foreign company

Slovak: “podnik” or “organizačná zložka podniku zahraničnej osoby”

Foreign persons may conduct business in Slovakia provided that they have their business or branch offices located in Slovakia, registered with the Slovak Commercial Register, from the day of its registration.

However, there are exceptions from the obligation to establish business or branch offices located in Slovakia for persons established in EU or EEA member states stipulated within the free movement of services guaranteed by the EU in Treaty on the Functioning of the European Union.

Simplified method of establishment of an enterprise or an organizational branch of a foreign company

As of February 1, 2023, in addition to the standard method of establishment of an enterprise or an organizational branch of a foreign company with its registered office in an EU or EEA state, there is introduced a simplified method of their establishment.

It is not possible to use this simplified method in all situations, but only if the conditions stipulated by law are fulfilled. The simplification consists in the elimination of one of the necessary steps prior registering an enterprise or an organizational branch of a foreign company in the commercial register, which is the obligation to apply to the Trade Licensing Authority for a trade licence certificate.

Consequently, on the basis of data from the information systems of public administration authorities, the Trade Licensing Authority shall issue a trade licence immediately after the registration of the enterprise or organizational branch of the foreign company in the commercial register. Registered persons may use this method of establishment only if they seek to register an object of business which is included in the relevant list according to the law.

The last but not least, it should be underlined that even in this simplified method of establishment it is necessary to verify integrity of a head of the enterprise or the organizational branch of the foreign company. In addition, foreign company has a bank account only at a bank, which has its registered office in one of the EU or EEA member states.

Exchange of information by the system of interconnection of registers

As of February 1, 2023, the registered court is obliged to notify to the commercial register or other register in which the foreign legal entity is registered or in which the foreign legal entity is obliged to file documents the registration of data or the deletion of data on the enterprise or on the organizational branch of a foreign legal entity with its registered office in one of the EU or EEA member states,  through the system of interconnection of registers.

Other forms of business

Legal forms of business entities primarily regulated by EU regulations, which are legally binding for all EU Member States:

  • European Company (or “SE”, Societas Europaea)
  • European Cooperative Society
  • European Economic Interest Group

A Limited Liability Company (in Slovak: spoločnosť s ručením obmedzeným) is the most used corporate form and is therefore dealt with in detail in the following parts.

Registration requirements

Registration procedure for company formation in Slovakia and documents

The procedure consists of the following phases:

  1. Establishment of the company by signing of:
  • the Memorandum of Association/Foundation Deed,
  • other required documents mainly as Signature Specimen of the persons who will form the statutory body; administrator´s declaration regarding the payment of the contributions,
  • approval for the premises of the registered seat in the Slovak Republic,
  • affidavit that the founders have no debts accrued on tax or stamp duties or in respect to payments of social security insurance, otherwise consent of the respective authority to the establishment of the company; this duty, however, does not apply to foreign nationals/companies.
  1. Acquisition of the necessary trade licences.
  2. Registration in the Commercial Register of the competent District court. Please note, that as of November 01, 2018, ultimate beneficial owners (UBOs) of a company about to be registered have to be specified in an application for registration of the company with the Commercial Register as a new AML requirement. For more information on legislation regarding ultimate beneficial owners, please refer to our Newsflash.

It is important to stress that a limited liability company acquires legal personality status upon its registration in the Commercial Register.

The incorporation time is approximately 3 weeks after the receipt of duly executed establishment documentation.

Requirements for foreign investors

The citizens of the EU or EEA (except Slovak citizens) who will form the statutory body have to prove their integrity by obtaining and submitting the criminal record from the state of citizenship or residency (if residing for longer than 6 months in other country than country of their citizenship).

The non-EU or non-EEA citizens, in order to become members of the statutory body, shall have a residence in Slovakia.

Under Slovak law, the company shall have registered seat in the territory of Slovakia. The document proving the seat (confirmation with the seat in the premises) is the obligatory annex to the Registration application.

Shareholders and statutory body

A Limited Liability Company may be established by a sole shareholder or by more shareholders, in both cases it is irrespective of whether they are a legal or a natural person. In respect of one shareholder there are the following restrictions:

  • a limited liability company owned by a sole shareholder must not be a sole shareholder in another limited liability company,
  • a natural person must not be a sole shareholder in more than three limited liability companies.

The maximum number of shareholders is limited to 50.

The registered capital must be at least of EUR 5,000 with a minimum contribution of EUR 750 of each shareholder. Contributions can be monetary or non-monetary, while an official appraiser must value a non-monetary contribution.

Minimum contribution
750 EUR

%

At least 30% of each shareholder’s monetary contribution, and in cases of non-monetary contributions at least 50%, must be paid up before the application for the registration of the Limited Liability Company is filed at the Commercial Register. The contributions do not have to be paid to the bank account and for the purposes of registration, the person administering the contributions will issue an affidavit declaring that the respective contributions have been paid up. If the Limited Liability Company is founded by a single entity, the registered capital must be paid up in full.

general meeting is composed of all shareholders and decides on all major issues as the appointment and dismissal of the executive directors, modification of the statutes and Memorandum of Association/Foundation Deed, increases and decreases of the registered capital.

The statutory body of the Limited Liability Company is formed by one or more executives (executive directors). Only a natural person can be appointed as an executive director. In the event that there are several executive directors, each of them is entitled to act individually on behalf of the company unless stipulated otherwise in the Memorandum of Association/Foundation Deed.

Establishment of a supervisory board is optional. If it is established, the supervisory board must be composed of at least three members appointed by the shareholders’ meeting.

Fees and penalties

The activity would be regarded as an unauthorized trading if the person systematically, independently, on own behalf, on own responsibility, for the purpose of earning profits, without holding a trade licence performs an activity subject to craft, regulated or unregulated trades or licenses.

The fine for unauthorized trading ranges from EUR 1,659 to EUR 3,319. Unauthorized trading can be also considered as an offence under the Slovak Criminal Code.

General overview of corporate taxes

The Slovak tax system comprises the following taxes:

Income taxes (personal income tax, corporate income tax)

Personal income tax

The tax rates applicable for income derived in 2024 are:

  • annual taxable income (except for income from business activity, capital and dividend income) up to EUR 47,537.98 is taxed at 19%
  • annual taxable income (except for income from business activity, capital and dividend income) above EUR 47,537.98 is taxed at 25%
  • income from business activity is taxed at reduced tax rate of 15%, if its annual taxable value does not exceed EUR 60,000 (note: in 2020 the threshold was EUR 100 thousand; between 2021 – 2023 the threshold was EUR 49,790); otherwise, 19% rate applies for taxable business income up to EUR 47,537.98 and 25% rate applies to the amount, which is above that threshold
  • income from capital is taxed at flat rate of 19%
  • income from dividends paid out of pre-2004 profits and profits derived from January 1, 2017 to December 31, 2023 is taxed at 7% (35% applies if dividends are from foreign sources of non-cooperating state).
  • income from dividends derived from profits for periods starting after January 1, 2024, a tax rate of 10% applies (while the rate of 35% still applies for dividends from foreign sources of non-cooperating states).

Moreover, an additional tax of 5% is to be paid by the representatives of constitutional bodies (e.g. the President, Members of Parliament) on their employment income.

Certain types of income are not aggregated but are subject to a final withholding tax of 19%, 10% or 7% in the case of dividends paid out by domestic company.

Corporate income tax

Corporate income tax is levied at a rate of 21%. However, since January 1st, 2021, taxpayers with taxable revenues not exceeding EUR 60,000 per tax period (note: in 2020 the threshold was EUR 100,000; between 2021 – 2023 the threshold was EUR 49,790) are entitled to apply reduced tax rate of 15%. This is the final tax burden on 2024 corporate profits in some cases because dividends paid out of 2024 profits are not taxed in the hands of shareholder if the shareholders are corporate and based in other than non-cooperating state.

Starting from the 2024 tax period, the minimum corporate tax (commonly known as tax licenses) has been reinstated in the tax legislation, following its abolition from 2017 to 2023. Legal entities are required to pay a minimum corporate tax of between EUR 340 and EUR 3,840 based on the amount of taxable income. Only a limited number of exceptions from the payment of the minimum tax are allowed, such as companies in bankruptcy, companies in their initial taxable period, non-profit organizations, etc.

Value added tax (VAT)

  • 20% is the standard VAT rate in Slovakia
  • 10% is the first reduced VAT rate
  • 5% is the second reduced VAT rate

Export of goods and services is zero rated.

Intra-Community supplies of goods are zero rated under certain conditions.

Excise duties

Excise duties are levied on mineral oil, beer, wine, spirits, electricity, coal, natural gas and tobacco products.

Motor vehicle tax

Levied on motor vehicles and trailers in categories L, M, N, and O if registered in Slovak Republic and used for business purposes.

Special taxes

Special taxes cover special duty paid by regulated industries and special levy on non-life insurance premium. Further, in 2023 and 2024, companies operating in the oil, gas, coal and refinery sectors shall pay a special solidarity contribution.

Moreover, there are local taxes to be paid, e.g. real estate tax.

For more details about taxation in Slovakia, download our free 2024 Tax Guideline!

Investment incentives 

Investment incentives are serious arguments in favour company formation in Slovakia. As an EU member country, Slovakia must ensure compliance with EU rules. In general investment incentives (or state aid) are linked to the region where the investment takes place and the European Commission has determined which regions are entitled to receive aid and the amount of aid each of those regions may receive. The connection with a certain region is one of the fundamental characteristics of the incentives and their provision shall serve to support not only foreign, but also Slovak investments.

In general, there are four categories of projects that can be supported by the investment incentives for company formation in Slovakia:

  • industrial production
  • technological centres
  • shared service centres
  • tourism

Each category has specifically defined conditions which shall be met in order to apply for the investment incentives. The incentives are provided in general in the form of:

  • a subsidy for the acquisition of material assets and immaterial assets
  • an income tax relief
  • a contribution for newly created jobs
  • transfer of immovable property or exchange of immovable property at a price lower than a general asset value

The provision of the state aid is governed in particular by the European Union law that forms the basic legal framework also for the Slovak authorities.

The Slovak real estate market was fully liberalized in May 2014, when the transition period negotiated between Slovakia and the European Union ended, boosting real estate transactions in Slovakia. The European law requires EU member states not to restrict acquisitions of real property by nationals of other member states, however during EU accession negotiations the Slovak Republic negotiated from this rule the temporary exemption concerning agricultural and forest land).

In general, Slovak citizens, Slovak companies (also with foreign owners), foreign citizens and foreign companies are allowed to purchase and sell real estates in Slovakia, however

All real estates located in Slovakia are registered in the Real Estate Registry and pursuant to the Cadastral Act, information registered in the Real Estate Registry is deemed reliable and binding unless the contrary is proved.

Real estate is evidenced on the respective Ownership Certificate, which includes following information: (i) information on real property; (ii) information on the owners and eventual co-ownership shares; and (iii) information on any encumbrances, pledges, easements and other rights of third persons to the real property.

The extract from Ownership Certificate may be obtained by everyone

Download our eBook on real estate transactions in Slovakia, or read more below

General information about real estate transfer process

The acquisition of real estate in Slovakia requires two obligatory steps:

execution of a written agreement,

registration of the title in the Real Estate Registry.

Execution of a written agreement for real estate transactions in Slovakia

The ownership of the real estate may be transferred by written purchase agreement concluded under the Slovak law. The demonstration of will to transfer the real estate of both the transferor and the transferee must be on the same document and the signature of the transferor shall be verified.

The purchase agreement can be drafted by either party and it does not need to be drafted by a public notary or certified attorney. The purchase agreement must include all the particulars required by the Civil Code and must also comply with the requirements of the Cadastral Act specifying more precisely its content.

The purchase agreement must be in Slovak language (or Czech language). Any other language version must be translated into Slovak by a certified translator, making it eligible to be registered in the Real Estate Registry.

Prior to the execution of the purchase agreement, the parties may conclude a preliminary agreement in which they undertake to enter a purchase agreement within the agreed time period. Based on the preliminary agreement, either party can sue for the performance of the purchase agreement if the other party breaches the obligation to enter in the purchase agreement.

Registration of the ownership title in the Real Estate Registry

The title to real estate is acquired by the registration in the Real Estate Registry upon the Resolution of the competent Real Estate Administration.

The registration process starts by the submission of the Application to the respective Real Estate Administrator and should be completed by the Resolution of the Real Estate Administration.

Usual scenario of the real estate transaction in Slovakia and applicable fees

In line with the established practice for real estate transactions in Slovakia

  1. Parties conclude a purchase agreement, the signature of the transferor shall be verified
  2. Parties regulate how the payment of the purchase price should be “secured” (from the signing of the agreement to the registration of the new ownership), for example:
    • Purchase price can be deposited in the notarial custody for the benefit of the transferor,
    • Purchase price can be deposited on escrow account administrated by a bank for the benefit of the transferor, and the purchase price will be paid to the transferor once the respective Resolution of the Real Estate Administration is issued
  3. Application is submitted to the respective Real Estate Administration. The Administration decides on the Application for the registration of the ownership title within 30 days, the fee is in the amount of EUR 66. The parties of the agreement can apply for registration in accelerated proceedings, in this case the fee is in the amount of EUR 266 and the registration is completed within 15 days.

Prohibition of fragmentation of a land

It is prohibited to create a new land as a result of the splitting up of existing land with an area of less than 3 000 m2 in the case of agricultural land and less than 5 000 m2 in the case of forest land.

Real estate transfer taxation

The table below provides a brief overview of fees and taxation with respect to the real estate transfer in Slovakia

TaxationSellerBuyer
IndividualCompany
IndividualCompany
Real estate transfer taxAs from 1 January 2005 a real estate transfer tax is not levied in Slovakia.
Real estate taxReal estate tax is levied on Slovak property, which comprises land, buildings and flats (apartments). In all cases, the tax liability arises on 1 January of the year following the year in which the property is acquired and ends on 31 December of the year in which the ownership ends.

 

The general rate of the land tax is 0.25% of the value. The general rate of the building tax and the apartment tax is EUR 0.033 per m2. The municipalities may increase or decrease these rates in accordance with the local conditions.

Value added taxThe delivery (sale) of construction or a part thereof in Slovakia by taxable person, including the supply of building land, on which the structure is constructed is subject to 20% VAT rate. Reduced VAT rate of 5% is applicable from January 1, 2023 in case of delivery of construction of a part thereof if special conditions for state-assisted rental housing are fulfilled. Exemption from VAT applies, if the delivery is carried out after laps of five years from the first use of the building. The VAT registered person may opt to charge the VAT. The seller is only entitled to a full input VAT deduction for services received related to the acquisition of real estate and the acquisition costs when the sale is subject to VAT. If input VAT was deducted, a VAT-exempt sale within 20 years leads to a pro-rata reversal of input VAT deduction.

 

Supply of land except for supply of building land by a taxable person is tax exempt. As long as the land is supplied along with the construction, the rules for the sale of construction applies.

Income tax

Tax residents are subject to Slovak personal income tax on their worldwide income, including income from real estate.

If real estate transaction qualifies as business activity, capital gains from selling the real estate would be fully taxable. If the activity is not qualified as a business activity, the sale of real estate within a period of 5 years is taxable. The tax base is the difference between sales price and acquisition costs (note: a loss cannot be claimed). A sale after expiration of the five-year holding period is not taxable.

The 19% or, as the case may be, the 25% tax rate applies.

For non-residents, income from transactions concerning domestic real estate is considered to be a Slovak sourced income and thus, they have to file tax returns. The 19% or, as the case may be, the 25% tax rate applies.

Tax resident company is subject to Slovak corporate income tax on its worldwide income, including income from real estate.

 

The income of corporations is to be regarded as business income in any case, regardless of the nature of the income (e.g. income from real estate). Capital gains from selling the real estates are taxable. The 21% flat tax rate applies. The loss upon a sale of some buildings and land cannot be claimed.

For non-residents, income from transactions concerning domestic real estate is considered to be a Slovak sourced income and thus, they have to file tax returns. The 21% tax rate applies.

Upon payment of purchase price for the Slovak real estate, generally no withholding tax applies. Some exceptions may apply if the recipient of the income is a foreign person from other than EU Member State or from outside the EEA.

If the purchased real estate will become part of the business assets, the acquisition costs must be generally capitalized and for buildings such acquisition costs can be according to the Slovak Income Tax Act depreciated over the period of 20 or 40 years (20 years period applies e.g. for industrial buildings, 40 years’ period applies e.g. for administrative buildings, hotels). Land plots are not depreciable.

Similar rules applies for non-residents as for tax residents.

Upon payment of purchase price for Slovak real estate, generally no withholding tax applies. Some exceptions may apply if the recipient of the income is a foreign person from other than EU Member State or from outside the EEA.

The acquisition costs must be generally capitalized and for buildings such acquisition costs can be according to the Slovak Income Tax Act depreciated over the period of 20 or 40 years (20 years period applies e.g. for industrial buildings, 40 years’ period applies e.g. for administrative buildings, hotels). Land plots are not depreciable.

Similar rules applies for non-residents as for tax residents.

Other aspects

Specificity

  1. Ownership of a land does not include ownership of a building located on it.

Slovak law does not recognize the principle according to which the ownership of a land includes the ownership of a building located on it. Consequently, the owner of a land may be different form the owners of the buildings on it.

  1. Due diligence

The real property ownership is registered in the Real Estate Registry.  A Resolution of the respective Real Estate Administration approving an entry in the Real Estate Registry and the registration of the transfer in the Real Estate Registry may not be considered as a guarantee that the ownership title was validly transferred, as there are several circumstances under which the transfer was in compliance with law.

Legislation for real estate transactions in Slovakia

  • The Act No. 40/1964 Coll., Civil Code, as amended
  • The Act No. 162/1995 Coll. on the real estate cadastre and entering of ownership and other rights to real estates, as amended (Cadastral Act)
  • The Act No. 140/2014 Coll. on acquiring the ownership of agricultural land, as amended
  • The Act no.180/1995 Coll. on some measures for land ownership arrangements, as amended

There are two types of bankruptcy proceedings in Slovakia for companies in financial difficulties:

Both types of procedures are governed by mandatory law that provides for transparency and the operation of the Slovak court in the procedures is considerable. Creditors as business partners of such companies shall be granted the possibility to claim receivables, which eventually may change the scenario, e.g. a company initiating the restructuring procedure may turn out to be insolvent and may be ultimately handled by virtue of bankruptcy proceedings in Slovakia.

Other procedures which lead to the deletion of the company from the Commercial Register are mainly:

Bankruptcy proceedings and restructuring proceedings are the procedures applicable in the case of the insolvency of the company and are therefore dealt in detail in the following parts.

Download our 2024 eBook on bankruptcy proceedings in Slovakia, or read more below

Filing an application by the company (as the debtor) or creditor

In case of the bankruptcy proceedings there are two insolvency tests under the Slovak legislation:

company is deemed insolvent if it is unable to fulfil at least two monetary obligations to more than one creditor 90 days after their due date

company is heavily indebted if it is obliged to keep accounts under a special regulation, has more than one creditor and the value of their obligations exceeded the value of their property

If the company is insolvent and/or heavily indebted, it is deemed bankrupt under Slovak law. Bankruptcy proceedings shall be initiated by the company (as the debtor) or may be initiated by its creditor.

In case the debtor had according to the last five financial statements neither liabilities nor assets in an amount that exceeds EUR 1,000,000 and other legal requirements are met, the so-called small bankruptcy shall be declared by the court. This proceeding is quicker and simpler than regular bankruptcy.

Obligation of the company (as the debtor) to apply for bankruptcy proceedings in Slovakia

The company (as the debtor) shall file a proposal for the bankruptcy order within 30 days since the company has known or while maintaining due diligence should have known its status, while

the obligation to file the application on behalf of the company (as the debtor) has the statutory body as well as the member of the statutory body of the debtor, liquidator of the debtor and the company’s legitimate representative

for the event of breach of the obligation to file a proposal for the bankruptcy in time there is a penalty in the amount of EUR 12,500.

The company (as the debtor) is required to submit a list of assets, list of liabilities, list of related parties and the most recent financial statements (if applicable) with the application. When the bankruptcy petition is filed by the company (as the debtor) and the decisive facts are well-documented, the decision of the court is straightforward.

Right of the creditor of the company to apply for bankruptcy proceedings in Slovakia

Bankruptcy proceedings may be initiated by the creditor, while the motion shall (i) describe the nature of the debt, which is 90 days overdue and the reasoning under which the creditor believes that the debtor is insolvent and (ii) identify another creditor of the company with a claim 90 days overdue.

It shall be noted that the claim of the creditor who is filling the application shall be duly proved in the motion in general by:

acknowledgment of the debt by the company (as the debtor) with the verified signature of the company (as the debtor),

final and non-appealable decision of a court or another authority,

confirmation of an auditor or of a court expert that the creditor accounts the receivable in accounting in accordance with accounting regulations.

The creditor who is filling the application shall not be obligated to prove his claim in the motion by abovementioned, if the creditor can reasonably presume the insolvency of his debtor or if the debtor is presumed to be insolvent due to the publication of a notice in the Commercial Gazette pursuant to a special regulation. The insolvency of the debtor may reasonably be presumed if the debtor has been in default for more than 90 days in the performance of at least two pecuniary obligations to more than one creditor and has been requested in writing by one of those creditors to pay.

In general, for the petition filed by the company or the creditor applies that the petitioner (company or the creditor) is required to make a deposit amounting to EUR 1,500 to cover the expected remuneration and expenses of the bankruptcy proceedings. The deposit shall be transferred to a bank account of the court prior to filing the petition in bankruptcy and a proof of payment of the deposit shall be included in the petition in bankruptcy. If the court dismisses the petition in bankruptcy or if prior to the commencement of the bankruptcy proceedings the petitioner withdraws its petition, the deposit shall be released to the petitioner.

In case of the restructuring proceedings the proceedings can be initiated by the company (as the debtor) or by its creditor.

Initiation of the restructuring proceedings by the company (as the debtor)

If the company´s (as the debtor) bankruptcy is impending or already is bankrupt, it may authorize an administrator to draw up the Restructuring Opinion in order to ascertain, whether the criteria for the restructuring of the company are met, or not (it does not affect the duty of the company to file a petition in bankruptcy in due time, if conditions for obligatory bankruptcy are met).

Initiation of the restructuring proceedings by the creditor

If one or several creditors agree with the company (as the debtor) to provide the necessary collaboration, they may authorize an administrator to prepare the Restructuring Opinion also on their own.

In both alternatives the administrator may recommend a restructuring of the company only if:

  • the company is already bankrupt,
  • it is reasonable to expect that at least a considerable part of the business of the company shall be maintained,
  • it is reasonable to expect that the extent of satisfaction of the creditors will be larger as if a bankruptcy order was made.

A petition asking for the authorization of the restructuring has to be filed with the court having jurisdiction. The restructuring petition may be filed by either the company (as the debtor) or by the creditor. Attached to the restructuring petition the petitioner shall file the Restructuring Opinion of the administrator.

Claiming receivables

The bankruptcy proceedings and restructuring proceedings start officially with the resolution of the court which is published in the Company Gazette (in Slovak: “Obchodný vestník”). The date of publication is also the starting date of the period during which creditors may submit their claims on receivables against the company

  • in the bankruptcy proceedings such period is 45 days. If the creditor delivers the application later to the administrator, the application shall be taken into consideration, but the creditor cannot exercise the voting right and other rights granted otherwise by law. The right to proportionate satisfaction of the creditor shall not be affected thereby, however it can be satisfied only from the proceeds included in the distribution plan from the general assets,
  • in the restructuring proceedings the period is 30 days. Any claim delivered after the expiration of the term shall be disregarded within the framework of the restructuring proceedings and the claim enforced thereby shall not be included in the Restructuring Plan.

In both procedures the submission of claims is free of charge. Each submitted claim shall be reconciled by the administrator with due care. If administrator finds out while analysing the claims, that any of them is disputable (as to the title of its existence or enforceability), the administrator shall be obliged to contest such claim to the extent in which it is disputable. However, the creditor holding a contested claim may file with the court an action asking the court to acknowledge the claim.

Final solution (possible options)

The objective of the bankruptcy proceedings is the termination of the company and the distribution of its assets. The administrator shall converse all the property of the company to funds in cash with the aim to satisfy the creditors. The proceeds from the sale of property shall be released to creditors holding proven claims, under a Distribution Scheme, which of course shall be approved by the respective body in the bankruptcy proceedings, respectively by the court.

Other possible final solutions in the bankruptcy proceedings may be mainly:

the court dismisses the petition in bankruptcy, if the petition in bankruptcy does not contain the essentials prescribed by the law and this deficiency was not removed in the stated period,

the court terminates the bankruptcy due to insufficient assets if it finds out that the property of the company (as the debtor) is not sufficient to cover at least the costs of the bankruptcy proceedings (i.e., EUR 6,500).

In the restructuring proceedings, a Restructuring Plan is prepared which includes two main sections: the descriptive part and the binding part which is crucial as it contains a specification of all rights and obligations to be constituted, altered or expired with respect to participants of the Restructuring Plan, such as prolongation of maturity, partial expiration of the obligations or instalments schedule.

The Restructuring Plan shall be approved by the creditors at the approval meeting and ratified by a decree of the course, once it was approved by the creditors.

Other possible final solutions in the restructuring proceedings may be that the court terminates the restructuring proceedings, if it finds out ex. g. that:

  • the final draft of the Restructuring Plan was not submitted to the creditor´s committee for preliminary approval within the statutory period,
  • the Restructuring Plan was not approved by the required quorum of the creditors at the approval meeting,
  • the plan submitter failed to file a petition to the court to have the plan confirmed by the court within the statutory period.

Property division rules

The property which is liable to the bankruptcy shall made up a bankruptcy estate, which shall be split between:

general assets

separated assets of secured creditors (receivables ex. g. secured by the pledge over the specific asset)

The creditors are satisfied by the funds which were converted by the sale of the assets from the respective group.

In general, the receivables are satisfied in the following order:

  • costs of the insolvency procedure which include mainly costs of selling the assets, remuneration of the administrator,
  • alimony,
  • employees’ wages and other claims of employees that arose after the bankruptcy was declared,
  • taxes, duties, health insurance payments, social insurance payments and other contributions to the state,
  • other claims.

In the restructuring proceedings is applied that the property is divided as it is proposed in the Restructuring Plan, which shall be approved by the creditors and subsequently ratified by the court.

According to the law, the rate of satisfaction of any of the unsecured receivables shall not be lower than 50% of the amount of the claim, this does not apply if the concerned creditor agrees in writing with a lower level of satisfaction.

Sanctions against debtor’s or creditor’s management

Sanctions on the side of the company (as the debtor)

Penalty for company´s (as the debtor) management

Company as the debtor is obliged to file a proposal for the bankruptcy order within 30 days since it knew or while maintaining due diligence should have known of its status. This obligation on behalf of the company (as debtor) has mainly the statutory body as well as the member of the statutory body of the company.

For the event of breach of the obligation to file a proposal for the bankruptcy in time, there is a fiction stipulated by the law, that between the company and the person obliged to file the proposal for the bankruptcy a contractual penalty in the amount of EUR 12,500 is negotiated. This sum serves for the satisfaction of bankruptcy costs and satisfaction of creditors (if the sum surpasses the bankruptcy costs). Any agreement between the company and the person obliged to file proposal for the bankruptcy, which excludes or restricts entitlement for the contractual penalty, shall be prohibited.

Entitlement for the contractual penalty shall not affect the entitlement to compensation for damage exceeding the contractual penalty.

Disqualification of the member of the statutory body to execute the function of the statutory

If the court decides that the person breached the obligation to file a proposal for the bankruptcy in time and therefore the person is obliged to pay the contractual penalty as described above, the person will be disqualified by the court to be a member of the statutory body of the company (as debtor) and also of other companies and the prohibition can be up to 3 years.

Further the person will be registered in the state Registry of Disqualification which is a public registry operated by the district court.

Criminal offenses on the side of the company (debtor)

There are several relevant criminal offenses according to Slovak Criminal Code concerning acting in insolvency status or in respect of the bankruptcy or restructuring proceedings, as:

  • Fraudulent insolvency
  • Culpable insolvency
  • Fraudulent conveyance of a creditor
  • Fraudulent preference of a creditor
  • Distortion of data in financial and business records
  • Deceitful practices in bankruptcy or restructuring proceedings
  • Obstructing bankruptcy or restructuring proceedings.

Sanctions on the side of the creditor

Criminal offenses for an improper acting in the bankruptcy or restructuring proceedings are mainly:

  • Deceitful practices in bankruptcy or restructuring proceedings
  • Obstructing bankruptcy or restructuring proceedings.

Sanctions for any third person

All third persons are obliged to collaborate under the Act of bankruptcy and restructuring. The collaboration shall be provided promptly and free of charge. If any third person fails to provide collaboration as required by the law, the court may penalize such person by a fine up to EUR 3,300.

Other aspects

Legal regulation:

  • Act No. 7/2005 Coll., Bankruptcy and Restructuring Act
  • Act No. 513/1991 Coll., Commercial Code
  • Act No. 300/2005 Coll., Criminal Code

The principal legislation regulating employment in Slovakia is the Labour Code. According to the Labour Code, employment relations shall be established by written employment contracts between an employer and employees. Besides an employment contract, the Labour Code recognizes three other contract types: work performance contract, work activities contract and temporary student job contract.

Download our 2024 guide on labour law and employment in Slovakia, or read more below

Entitlement to work in Slovakia

Pursuant to the Act on Illegal employment, it is prohibited for an employer to employ persons without an established employment relationship. This is applicable for all types of individuals bellow:

  • Slovak citizens,
  • citizens of European Union (“EU”) or of contracting states of the Agreement on the European Economic Area and Switzerland (“EEA”),
  • non-EU and non-EEA citizens.

A third-country national has the same right to use employment services as a citizen of Slovakia, with the following restrictions:

EU citizens

EU citizens are entitled to stay in Slovakia without any conditions or formalities for three months after the date of entry into the territory of Slovakia.

An EU citizen staying in Slovakia for more than three months is required to apply for registration of residence in Slovakia, while one of the reasons under which an EU citizen is authorized to stay in Slovakia is, for example, an employment in Slovakia.

NON-EU citizens

Citizens of other countries than the EU or EEA countries are entitled to work in Slovakia if they meet the specific conditions set by legislation (e. g. to have a work permit / temporary residence permit for the purpose of employment).

Throughout 2018 have been introduced several new regulations to make employment of non-EU citizens more flexible in areas of industry with lack of workforce, in particular in relation to shortening the time periods for granting of temporary residence permits and reducing of a related administrative burden.

Employment contracts

Minimum specifications

The employment contract contains the employer’s and employee’s identification details. In order to conclude an employment contract, the employer and the future employee need to agree on the following minimum specifications that will be included in the contract:

job description

place of work or places of work, if more than one, or the rule that the place of work shall be determined by the employee

date on which employment commences

the salary (unless this has been agreed in a collective bargaining agreement)

Information about employment terms and conditions

With regard to other essentials, such as the method of determining the place of work in the case of multiple workplaces, the scheduling of working time, the amount of leave, the payment of wages and pay dates, the employer may decide whether to specify them in the employment contract or to provide them to the employee in the written form (or in electronic form, if this is possible under the law) or by reference to the relevant provisions of the Labour Code. In case the information is not directly contained in the employment contract, the employer is obliged to provide the employee with given information within the period of 7 days or 4 weeks, depending on the type of information to be provided.

Obligations

On taking up the employment, an employer is obliged to acquaint the employee with work rules, health and safety regulations and collective agreements, if any.

Pursuant to the Act on Illegal work and illegal employment, it is prohibited for an employer to employ persons without an established employment relationship.

Contract duration

The employment contracts in Slovakia can be concluded for:

Definite period

Indefinite period

The Labour Code contains certain limitations in respect to the employment contract concluded for definite period of time. Such contracts can be concluded for a maximum of two years and it is possible to extend them or conclude them again only twice within these two years. The limited duration (i.e. definite period of time) of the contract must be agreed in writing in the contract, otherwise the contract is deemed to be concluded for indefinite period.

Probationary Period

The parties can agree on an initial probationary period of:

General employees
Maximum 3 months

%
Certain managerial positions
Maximum 6 months

%

Termination of employment

Cases

mutual agreement

immediate termination

  • the employer must terminate the employment within two months since becoming aware of the grounds for the immediate termination, and at the latest within one year of the day on which those grounds arose
  • this method of termination of employment relationship can be used only in exceptional circumstances stipulated by the Labour Code

termination in the probationary period

  • by both the employer or employee who may terminate the employment during probationary period without providing any reason for termination
  • by a written notice that should be given and delivered to the other party at least 3 days before the day of stipulated termination

notice

  • both employer and employee may terminate an employment contract by a written notice
  • the employee may terminate the employment contract for any reason or without stating any reasons
  • the employer may terminate the employment contract only in the situations expressly stipulated in the Labour Code

The employment contract terminates also:

by lapse of time in case of the employment contract concluded for definite period

expiry of residence permit in case of foreign employees, either by virtue of time or revocation.

Notice period

Both employer and employee may terminate an employment contract by a written notice. As mentioned above, the employee may terminate the employment contract for any reason or without stating any reasons. On the other hand, the employer may terminate the employment contract only in the situations expressly stipulated in the Labour Code:

  • The employer or its part:
    • is being wound up or
    • relocated and the employee does not agree with the change of the agreed place of work.
  • The employee has become redundant because of a written decision of the employer or a competent authority to change the employer’s function, its technical equipment, or to reduce the number of employees in order to ensure labour efficiency, or other organisational changes, and the employer that is a temporary employment agency may also give notice to an employee if the employee has become redundant with regard to the termination of the temporary secondment prior to the expiry of the period for which the employment for a definite period of time was agreed,
  • with regard to his or her medical fitness pursuant to medical opinion the employee has lost, for an extended period, his or her capacity to carry out their current work or must not carry out such work because of an existing occupational disease or the risk of occupational disease, or if the employee has reached in his or her workplace the maximum permissible exposure as determined by decision of a competent public health authority.
  • The employee:
    • does not satisfy the prerequisites for the agreed work provided in legal regulations,
    • has ceased to satisfy the requirements referred to in Section 42 Subsection 2 of Labour Code,
    • does not satisfy, without any fault of the employer, the requirements for properly carrying out the agreed work as determined by the employer in its internal regulation, or
    • performs his or her work tasks in a dissatisfactory manner and during the last six months the employer has delivered to the employee a written notice requesting him or her to remedy such underperformance and the employee has failed to remedy it within a reasonable time,
  • reasons exist in relation to the employee for which the employer could have terminated his or her employment with immediate effect, or could have terminated it for a less serious breach of work discipline; notice may be given to an employee on the grounds of a less serious breach of work discipline if the employee has been notified in writing during the last six months of the possibility of termination of employment.
  • the employee has reached the age of 65 and the age for entitlement to a retirement pension; however, in December 2021 the Constitutional Court of the Slovak Republic decided to suspend the effectiveness of this Article of the Labour Code, which means that the provision of the law in question will not apply from January 1, 2022 and employers are therefore not able to use it. In the following months, the Constitutional Court will decide whether the given provision of the Labour Code is in accordance with the Constitution of the Slovak Republic and will therefore enter into force or is not in accordance with the Constitution of the Slovak Republic and will be deleted.
  • The general length of the notice period for a Slovak labour contract is:
    • the statutory minimum notice period is 1 month (unless longer notice period is stipulated by the Labour Code),
    • 2 months, if the employee was employed for at least 1 year but less than 5 years,
    • 3 months, if the employee was employed for at least 5 years.
    • Longer statutory notice period depends on the length of employment and the reason of its termination.

Social contributions and income tax

Social contributions

The employer is obliged to pay monthly contributions to health insurance, social insurance and advances on the income tax. The amounts of contributions are presented in the table below.

Payrolls and Contribution Employee rate Employer rate Maximum monthly assessment base
Sickness insurance 1.40% 1.40% EUR 9,128
Pension contribution 4.00% 14.00% EUR 9,128
Disability insurance 3.00% 3.00% EUR 9,128
Unemployment insurance 1.00% 0.50% EUR 9,128
Insurance to finance support during short-time work 0.50% EUR 9,128
Guarantee insurance 0.25% EUR 9,128
Accident insurance 0.80% unlimited
Reserve fund 4.75% EUR 9,128
Health insurance 4.00% 11.00% unlimited
TOTAL
13.40% 36.20%  

Please note that as of January 1st, 2024 the minimum monthly wage in Slovakia is EUR 750 in case of the 1st degree of labour difficulty. The minimum wage depends on the degree of labour difficulty rating. Minimum hourly wage is EUR 4.310.

Income tax

An individual’s tax liability is derived from the taxable income. Slovak tax residents are liable to personal income tax on their worldwide income, subject to provisions under applicable double taxation treaties. The tax year is the calendar year and the income is taxed at a progressive tax rate of 19 % and 25 %.

The tax rates applicable for income derived in 2024 are:

  • annual taxable income (except for income from business activity, capital and dividend income) up to EUR 47,537.98 is taxed at 19%,
  • annual taxable income (except for income from business activity, capital and dividend income) above EUR 47,537.98 is taxed at 25%.

Working time and vacation

Regular working time

The maximum weekly working time is 40 hours, employees working on the basis of a two-shift system may work up to 38.75 hours per week and employees working on a three-shift system or who are involved in continuous operation may work up to 37.5 hours per week. It is also possible to agree on an uneven distribution of working time with the representatives of the employees.

Overtime

In general, upon agreement with the employer, employees may perform overtime work. Overtime work may reach up to 400 hours per calendar year. Of this time, the employer may order the overtime work in the extent of up to 150 hours per calendar year, the remainder of overtime work shall be agreed with the employee. For the work performed in excess of the standard working time, the employee is entitled to an allowance, specifics of which are regulated in the Labour Code.

Time off

Any employee who works for the same employer constantly for at least 60 days in a calendar year is entitled to annual paid leave on a proportionate basis. The basic annual leave entitlement is at least 4 weeks, rising up to 5 weeks for employees who are 33 years old or older (already in the year in that the employee reaches the age of 33, regardless of the birth date of the employee) and an employee who is permanently taking care of a child.

From 2022, employees who permanently take care of a child are entitled to an aliquot of 365 days, according to the number of days counting from the date they permanently take care of a child and date of its written announcement to their employer. For example, if the child was born in the 200th day of the year and its parents announced it to the employer at the exact day of its birth, they are then entitled to: 200/365 days * 5 = 2.75, which is 3 days of extra time off after rounding.

Most common employee benefits

Benefits include cash benefits and non-cash benefits provided by the employer to the employee.

The cash benefit refers to the financial bonus on top of the standard wage or salary.

The most common non-cash benefits in Slovakia are:

company cars also for private use

meal tickets with the remittance of the employer

extra holiday

company computers or mobile telephones also for private use

flexible working hours or optional home working

reimbursement of sporting and cultural events

contribution to old-age pension scheme

premium health care

Meal allowance up to the statutory limit is exempt from tax. As of March 2021, the employer is obliged to allow his employees to choose between a meal voucher or a financial contribution for meal. As of January 2023, the employer can only provide meal voucher to employees in electronic form. Paper meal voucher may only be used if the use of a gastrocard (electronic form of meal voucher) at or near the employee’s workplace during the work shift would not be possible. The amount of the financial contribution for meal should be the same as the amount in which the employer contributes to the meal voucher to other employees (on the comparable job positions).

Effective from January 1, 2022 there is a new type of exemption from personal income taxation applicable. Specifically, benefits in kind, i.e. non-cash benefits (e.g. team-building activities, firm events, gifts to employees etc.) provided to an employee of up to EUR 500 from all employers in a calendar year can be exempt from taxation, provided that costs of such benefits in kind are treated as tax non-deductible costs for the purpose of employer’s corporate income tax.

As of January 2024, non-cash benefit in form of the employee shares or in the form of a business share in an LLC are exempt from income tax, if the comapny has not paid dividends so far; and these employee shares have not been/are not listed on a regulated market until the end of the tax year in which the benefit was acquired by the employee.

Temporary work characteristics

Special types of contracts

Besides an employment contract, the Labour Code recognizes three other contract types: (a) Work performance contract, (b) Work activities contract and (c) Temporary student job contract.

As of November 2022, the work conditions have to be transparent, which means in case of mentioned contracts that the employee must be informed about the days and time periods during which the employer may require him/her to perform work. Also, it will be no longer possible to require these persons to come to the workplace as soon as possible, if necessary, since the amendment introduced a period of at least 24 hours prior notice by which the employer will be obliged to inform the employee about assigned work task. Even in this case, the employee will need to be informed in writing of any change at the latest on the day it takes effect. If the employer fails to comply with these conditions, the employee will be entitled to refuse to perform such work. On the other hand, if the employer cancels the work without giving less than 24 hours’ prior notice, the employee will be entitled to a refund of at least 30% of the remuneration he would normally receive.

Work performance contract

The work performance contract may be concluded if the anticipated extent of work (work tasks) for which the agreement is concluded is not in excess of 350 hours in a calendar year. It can be concluded for maximum 12 months.

Work activities contract

Under the work activities contract the working period may not exceed 10 hours per week and the contract can be concluded for maximum 12 months.

As of January 2023, in the case of the performance of seasonal work under Annex 1b of the Labour Code, a new type of work activities contract may be concluded, which for these purposes is referred to as a work activities contract for the performance of seasonal work. The working period may not exceed 520 hours per calendar year and the weekly average working time for the duration of that contract, up to a maximum of four months, may not exceed 40 hours. The contract can be concluded for maximum 8 months.

Temporary student job contract

The temporary student job contract can be concluded only with a person with the status of student, who is under the age of 26 years. Work performance may not exceed 20 hours per week and the contract can be concluded for maximum 12 months.

Personnel leasing

Temporary assignment (personnel leasing) is also one form of employing individuals. This is a flexible form of employment where employees are temporary assigned to a so-called user employer, while the employee is in employment relationship with another employer or a temporary employment agency.

A temporary employee cannot be assigned to a particular user employer for more than 24 months.  Subject to that 24-month limit, a temporary assignment of a temporary employee to a particular user employer can be extended or renewed up to four times. A temporary employee is entitled to be paid at the same rate as the user employer’s core employees. If there is a difference between those pay rates, the user employer is obliged to pay any shortfall to the temporary employee. The user employer is not permitted to assign a temporary employee on to another user employer.

Overview of applicable legislation

  • The Labour Code
  • Act on Illegal Employment
  • Occupational Safety and Health Protection Act
  • Act on International Cooperation when Posting Employees
  • Act on Travel Allowances

When doing business in Slovakia, you should always pay extra attention to the most important tax deadlines and other statutory obligations due to the increase of inspections in the recent years. Our experts prepared a comprehensive calendar for an easy overview of duties, to keep you updated and avoid penalties.

For a more detailed overview on taxation in the respective country, we would like to draw your attention to our latest 2024 Tax guideline for Slovakia.

Download the calendar, or read more below

January 2024

January 2

VAT

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

  • Payment of quarterly advances for income tax in the amount of 1/4 of tax – by natural persons whose amount of tax for the previous tax period exceeded EUR 5,000 and was less than EUR 16,600

Corporate income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

  • Payment of quarterly advances for income tax in the amount of 1/4 of tax – by legal persons whose amount of tax for the previous tax period exceeded EUR 5,000 and was less than EUR 16,600

Income tax from dependent activity

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

  • Payment of quarterly advances on motor vehicle tax in the amount of 1/4 of estimated tax – by taxpayer whose estimated tax paid to one tax authority exceeds EUR 700 and is less than EUR 8,300

January 15

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

January 25

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Quarterly VAT payers – VAT return submission and payment of VAT liability for previous calendar quarter

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of EC Sales List – quarterly VAT payers providing services to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

  • Submission of  VAT Ledger Report –  natural persons who are quarterly VAT payers

January 31

VAT

  • Submission of OSS VAT return for the previous calendar quarter for distance sell of goods within the EU and payment of such tax

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

Corporate income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

Income tax from dependent activity

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Submission of tax return on motor vehicle tax for 2023 and payment of the tax resulting from the annual tax return for 2023

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

  • Submission of notification of termination of the obligation to pay tax according to § 8 par. 7 of the Act

Real estate tax

  • Submission of the tax return (or partial tax return) for the real estate tax

Insurance premium tax

  • Submission of the quarterly tax return and payment for the insurance premium tax

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

February 2024

February 12

Income tax from dependent activity

  • Obligation of the employer to issue a certificate of taxable income of the employee for 2022, if the employee requested it by February 5, 2024

February 15

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

February 26

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

February 28

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

Corporate income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

Income tax from dependent activity

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

February 29

VAT

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

March 2024

March 11

Income tax from dependent activity

  • Obligation of the employer to issue a certificate of taxable income of the employee for 2023 for the purposes of employee´s income tax return submission for 2023

March 15

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

March 25

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

April 2024

April 2

VAT

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Submission of tax return on personal income tax and payment of tax resulting from the tax return for 2023

  • Submission of a notification of an extension of the deadline for submitting a tax return for the tax period of 2023

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

  • Payment of quarterly advances for income tax in the amount of 1/4 of tax – by natural persons whose amount of tax for the previous tax period exceeded EUR 5,000 and was less than EUR 16,600

Corporate income tax

  • Submission of tax return on corporate income tax and payment of tax resulting from the tax return for 2023

  • Submission of a notification of an extension of the deadline for submitting a tax return for the tax period of 2023

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

  • Payment of quarterly advances for income tax in the amount of 1/4 of tax – by legal persons whose amount of tax for the previous tax period exceeded EUR 5,000 and was less than EUR 16,600

Income tax from dependent activity

  • The employer’s obligation to make an annual settlement of tax advances for 2023 at the request of the employee

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

  • Payment of quarterly advances on motor vehicle tax in the amount of 1/4 of estimated tax – by taxpayer whose estimated tax paid to one tax authority exceeds EUR 700 and is less than EUR 8,300

Corporate responsibilities

  • Compilation of financial statements for 2023 and its entry in the register of financial statements

April 15

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

Income tax from dependent activity

  • Obligation of the employer to issue at the request of the employee a “Certificate of payment of tax for the purposes of § 50”

April 25

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Quarterly VAT payers – VAT return submission and payment of VAT liability for previous calendar quarter

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of EC Sales List – quarterly VAT payers providing services to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

  • Submission of VAT Ledger Report –  natural persons who are quarterly VAT payers

April 30

VAT

  • Submission of OSS VAT return for the previous calendar quarter for distance sell of goods within the EU and payment of such tax

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

  • Submission of a declaration of a natural person, in the case of a taxpayer to whom the employer has made an annual settlement to remit 2% (3%) of the paid income tax for the year 2023 to the designated beneficiary

Corporate income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

Income tax from dependent activity

  • Obligation of the employer to deliver to the employee a document on the performed annual settlement of tax advances for 2023

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

  • Submission of a report on the tax statement and on the total income from dependent activity for 2023

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

Insurance premium tax

  • Submission of the quarterly tax return and payment for the insurance premium tax

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

May 2024

May 15

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

May 27

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

May 31

VAT

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

Corporate income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

Income tax from dependent activity

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

June 2024

June 17

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

June 25

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

July 2024

July 1

VAT

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

  • Payment of quarterly advances for income tax in the amount of 1/4 of tax – by natural persons whose amount of tax for the previous tax period exceeded EUR 5,000 and was less than EUR 16,600

Corporate income tax

  • Submission of a tax return and payment of the tax resulting from the tax return for 2023, if the taxpayer extended the deadline for submitting the tax return by June 30, 2024

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

  • Payment of quarterly advances for income tax in the amount of 1/4 of tax – by legal persons whose amount of tax for the previous tax period exceeded EUR 5,000 and was less than EUR 16,600

Income tax from dependent activity

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

  • Payment of quarterly advances on motor vehicle tax in the amount of 1/4 of estimated tax – by taxpayer whose estimated tax paid to one tax authority exceeds EUR 700 and is less than EUR 8,300

Corporate responsibilities

  • Compilation of financial statements for 2023 and its entry in the register of financial statements, if the company has extended the deadline for submitting a tax return for income tax for 2023 until June 30, 2024

July 15

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

July 25

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Quarterly VAT payers – VAT return submission and payment of VAT liability for previous calendar quarter

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of EC Sales List – quarterly VAT payers providing services to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

  • Submission of VAT Ledger Report –  natural persons who are quarterly VAT payers

July 31

VAT

  • Submission of OSS VAT return for the previous calendar quarter for distance sell of goods within the EU and payment of such tax

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

  • Submission of a tax return on personal income and payment of the tax resulting from the tax return for 2023, if the taxpayer extended the deadline for submitting the tax return by June 30, 2024

Corporate income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

Income tax from dependent activity

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

Insurance premium tax

  • Submission of the quarterly tax return and payment for the insurance premium tax

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

August 2024

August 15

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

August 26

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

September 2024

September 2

VAT

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

Corporate income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

Income tax from dependent activity

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

September 16

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

September 25

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

September 30

VAT

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

  • Payment of quarterly advances for income tax in the amount of 1/4 of tax – by natural persons whose amount of tax for the previous tax period exceeded EUR 5,000 and was less than EUR 16,600

Corporate income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

  • Payment of quarterly advances for income tax in the amount of 1/4 of tax – by legal persons whose amount of tax for the previous tax period exceeded EUR 5,000 and was less than EUR 16,600

Income tax from dependent activity

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

  • Payment of quarterly advances on motor vehicle tax in the amount of 1/4 of estimated tax – by taxpayer whose estimated tax paid to one tax authority exceeds EUR 700 and is less than EUR 8,300

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

October 2024

October 15

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

October 25

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Quarterly VAT payers – VAT return submission and payment of VAT liability for previous calendar quarter

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of EC Sales List – quarterly VAT payers providing services to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

  • Submission of VAT Ledger Report –  natural persons who are quarterly VAT payers

October 31

VAT

  • Submission of OSS VAT return for the previous calendar quarter for distance sell of goods within the EU and payment of such tax

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

Corporate income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

Income tax from dependent activity

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

Insurance premium tax

  • Submission of the quarterly tax return and payment for the insurance premium tax

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

November 2024

November 15

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

November 25

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

December 2024

December 2

VAT

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600

Corporate income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600

Income tax from dependent activity

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300

December 16

Intrastat

  • Submission of report for the arrival/dispatch of goods within EU (Intrastat report) for the previous month to the customs authorities

Personal income tax

  • Payment of the amount for provision of personal income tax by the income payers and notification of this fact to the relevant tax office

Corporate income tax

  • Payment of the amount to secure the tax return on corporate income by the payer of the income and notification of this fact to the tax office

December 27

VAT

  • Monthly VAT payers – VAT return submission and payment of VAT liability for previous calendar month

  • Submission of EC Sales List – monthly VAT payers and quarterly VAT payers selling goods to other EU member states

  • Submission of VAT Ledger Report – legal persons who are both monthly and quarterly VAT payers and natural persons who are monthly VAT payers

December 31

VAT

  • Submission of OSS VAT return for the previous calendar month for distance sell of goods imported from third countries and payment of such tax

Personal income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by natural persons whose last known tax obligation exceeded the amount of EUR 16,600
  • Payment of quarterly advances for income tax in the amount of 1/4 of tax – by natural persons whose amount of tax for the previous tax period exceeded EUR 5,000 and was less than EUR 16,600

Corporate income tax

  • Payment of monthly advances for income tax in the amount of 1/12 of tax for the previous tax period – by legal persons whose last known tax obligation exceeded the amount of EUR 16,600
  • Payment of quarterly advances for income tax in the amount of 1/4 of tax – by legal persons whose amount of tax for the previous tax period exceeded EUR 5,000 and was less than EUR 16,600

Income tax from dependent activity

  • Submission of an overview of deducted and paid advances to income tax from dependent activity for the previous calendar month

Motor vehicle tax

  • Payment of monthly advances on motor vehicle tax, in the amount of 1/12 of estimated tax – by the taxpayer whose estimated tax paid to one tax authority exceeds the amount of EUR 8,300
  • Payment of quarterly advances on motor vehicle tax in the amount of 1/4 of estimated tax – by taxpayer whose estimated tax paid to one tax authority exceeds EUR 700 and is less than EUR 8,300

Within 5 days after the payout date

Income tax from dependent activity

  • Payment of advances on income tax from dependent activity for employees

On the day intended for the payment of income

Social and health contributions

  • Advance payment for health insurance for the previous calendar month.

  • Advance payment for social insurance for the previous calendar month.

If you are tempted by the new business opportunities of Central and Eastern Europe (CEE), Slovakia should definitely rank high in your destinations list. The long term political stability, strategic location, common European currency, competitive taxation system, highly skilled workforce – along with the already well-established international business community – makes Slovakia one of the most attractive countries in the CEE region.

Download our 2024 Tax Guideline for Slovakia or read more below

Legal forms of business and their characteristics

General rules on purchasing of real estate

The real estate investor can acquire Slovak real estate by way of an asset deal (e.g. direct acquisition of real estate) or a share deal (e.g. acquisition of a corporation owning real estate).

Share deal

In case investment is done through a resident corporation it is worth mentioning that with respect to profits derived from January 1, 2004 to December 31, 2016 Slovakia has a single taxation system, i.e. corporate profits were fully taxed at the company level and distributed profits are not taxed in the hands of the corporate or individual shareholders. With respect to profits derived from January 1st, 2017 the single taxation system applies in the case of corporate shareholder only if the shareholder is based in other than non-cooperating state.

General and limited partnerships are also legal entities for corporate income tax purposes. However, general partnerships are taxed only on income that is subject to withholding tax and their other profits are taxed in the hands of the general partners. Limited partnerships are subject to corporate income tax only on the income attributable to the limited element of the partnership, and the other part of the income is taxed in the hands of the general partners.

Asset deal

Foreign entities (natural or legal) may directly acquire real estate in Slovakia, except from:

Land belonging to the Agricultural or Forest Land Sources located outside district build-up area (some exceptions are allowed)

Specific real estate property purchase of which is limited by law (e.g. caves, rivers, etc.)

No real estate transfer tax is applied.

Legal forms of business

The form of business

The minimum capital

Tax treatment

Tax rates

 
English Slovak  

General Partnership

Verejná obchodná spoločnosť (v.o.s.)

Income tax base is calculated at the level of the partnership and then transferred to partners; tax is levied at the level of the partners.

15% / 19 % / 25%1) or 15% / 21%2)

 

Limited Partnership

Komanditná spoločnosť (k.s.)

EUR 250 / minimum deposit of limited partner

Tax resident, however, income tax base attributable to general partners is transferred to general partners and tax is levied at the level of general partners.

15% / 19 % / 25%1) or 15% / 21%2)

 

15% / 21%3)

 

Limited Liability Company

Spoločnosť s ručením obmedzeným (s.r.o.)

EUR 5,000

EUR 750 / minimum deposit of limited partner

Non-transparent, dividends from 2004-2016 profits not subject to tax, dividends from profits derived from 1/1/2017 subject to tax4)

15% / 21%5)

 

Joint Stock Company

Akciová spoločnosť (a.s.)

EUR 25,000

Non-transparent, dividends from 2004-2016 profits not subject to tax, dividends from profits derived from 1/1/2017 subject to tax4)

15% / 21%5)

 

Simple joint stock company (new form introduced from 2017)

Jednoduchá spoločnosť na akcie (j.s.a.)

EUR 1

Non-transparent, dividends subject to tax4)

15% / 21%5)

 

Cooperative

Družstvo

EUR 1,250

Non-transparent, dividends from 2004-2016 profits not subject to tax, dividends from profits derived from 1/1/2017 subject to tax4).

15% / 21%5)

 

Sole entrepreneur

Živnosť

Tax liability of sole entrepreneur.

15% / 19 % / 25%6)

 
  1. In case the general partners are individuals, progressive personal income tax rates (19%, 25%) apply, if total annual taxable value of business income of the individual exceeds EUR 60,000 (note: in 2020 the threshold was EUR 100,000; between 2021 – 2023 the threshold was EUR 49,790). Otherwise, 15% tax rate shall apply.
  2. In case the general partners are corporations, the corporate income tax rate of 21% applies, if total taxable revenues of the corporation exceed EUR 60,000 per tax period (note: in 2020 the threshold was EUR 100,000; between 2021 – 2023 the threshold was EUR 49,790). Otherwise, 15% tax rate shall apply.
  3. Tax base attributable to limited partners is taxed at the level of the partnership at 21% corporate income tax rate, if its total taxable revenues exceed EUR 60,000 per tax period (note: in 2020 the threshold was EUR 100,000; between 2021 – 2023 the threshold was EUR 49,790). Otherwise, 15% tax rate shall apply.
  4. Starting January 1, 2017 dividends paid to individuals, residents and non-residents are subject to withholding tax. Lasting from January 1, 2024 the applicable tax rate increased to 10 % (for tax periods 2017 – 2023 were dividends subject to withholding tax at the rate of 7%) if the applicable double tax treaty does not determine otherwise. If the recipient is an individual from the non-cooperating state, the tax rate of 35% shall apply. Dividends paid to foreign companies based in non-cooperating states shall be subject to a 35% withholding tax (note: In other cases exemption applies.)
  5. If total taxable revenues of the legal entity exceed EUR 60,000 per tax period (note: in 2020 the threshold was EUR 100,000; between 2021 – 2023 the threshold was EUR 49,790), the corporate income tax rate of 21% shall apply. Otherwise, the legal entity is entitled to apply reduced tax rate of 15%.
  6. If total annual taxable value of business income of the individual exceeds EUR 60,000 (note: in 2020 the threshold was EUR 100,000; between 2021 – 2023 the threshold was EUR 49,790), progressive income tax rates (19%, 25%) apply. Otherwise, reduced tax rate of 15% shall apply for taxation of business income.

Social security and labour law aspects

General social security and health insurance

Contribution for

Maximum base per month in EUR

Employee

Employer

Sole entrepreneur

Pension insurance

9,128 1)

4.00%

14.00%

18%

Disability insurance

9,128 1)

3.00%

3.00%

6%

Reserve fund

9,128 1)

4.75%

4,75%

Sick leave insurance

9,128 1)

1.40%

1.40%

4,4%

Accident insurance

No maximum

0.80%

Unemployment insurance

9,128 1)

1.00%

1.00%

2% 2)

Guarantee fund

9,128 1)

0.25%

Health insurance 3)

No maximum 1)

4.00%

11.00% 4)

15% 4)

TOTAL

 

13.4%

35.2%

49,15%

  1. The maximum assessment base was abolished as of January 1, 2017 only for health insurance; for social insurance it was increased to 7-times the average wage in Slovakia. The minimum assessment base for the employee and the employer is not defined and; for the sole entrepreneur it is EUR 652 starting January 1, 2024.
  2. The contribution is voluntary.
  3. Starting from January 1, 2011 it was introduced that dividends are also subject to the health insurance contributions if they are paid on the account of individuals obligatorily insured for health insurance purposes in Slovakia. This applies to dividends paid out of profits generated from January 1, 2011 to January 31, 2016. Also dividends paid out of profits generated before January 1, 2004 are subject to health insurance contributions. Starting from January 1, 2024 the maximum annual assessment base is EUR 78,240. Dividends paid out from profits generated from January 1, 2017 are not subject to health insurance at all.
  4. The rate of health insurance contributions increased as of January 1, 2024 for the contributions paid by employer from 10.00% to 11.00% and for the contributions paid by sole entrepreneur from 14.00% to 15.00%.

Persons residing in the EU are subject to the provisions of EC Regulation 883/2004, which provide for the applicable social security regulation in the case of cross-border activities. If non-EU residents work in Slovakia or Slovak nationals work in a third country, a bilateral social security agreement may provide for the applicable social security legislation.

General comments on labour law

Main features of employment relationship

Applicable law on labor

Contract type

Fixed-term contract, contract for indefinite period of time, contract on reduced working hours, contract on home-work and tele-work, temporary assignation agreement, work performance agreement, agreement on work activity, agreement on student job

  • Act No. 311/2001 Coll. Labour Code
  • Act No. 461/2003 Coll. on social insurance
  • Act No. 580/2004 Coll. on health insurance
  • Act No. 663/2007 Coll. on minimum salary
  • Act No. 283/2002 Coll. on travel expenses
  • Act No. 124/2006 Coll. on safety and health protection at work
  • Act No. 82/2005 Coll. on illegal work and illegal employment
Act No. 125/2006 Coll. on labour inspection

Contract must include

Job description, place of work, start date, payment conditions, pay day, working hours, holiday duration, length of termination notice period

Working time

40 hours per week (subject to some exceptions in case of specific working environments)

Holiday entitlement per year

20 days and 25 days in case (1) of employee of 33 years and older (already from the year in which the employee reaches the age of 33) or (2) of a parent taking care of child

Other comments

Trial period (max. 3 or max. 6 months for employees directly subordinated to chief executive officers), statutory rules in case of employment termination, termination period (minimum of 1, according to duration of the labour relationship 2 or 3 months)

Taxes on corporate income

Corporate income tax – rates

Income and capital gains

Corporate income tax is levied at a rate of 21%. There is a also a 15% reduced rate. Since January 1, 2024, taxpayers with taxable revenues not exceeding EUR 60,000 per tax period (note: in 2020 the threshold was EUR 100,000; between 2021 – 2023 the threshold was EUR 49,790) are entitled to apply the 15% reduced tax rate.

This is the final tax burden on 2024 corporate profits in some cases because dividends paid out of 2024 profits are not taxed in the hands of shareholder if the shareholders are corporate and based in other than non-cooperating state.

Starting from the 2024 tax period, the minimum corporate tax (commonly known as tax licenses) has been reinstated in the tax legislation, following its abolition from 2017 to 2023.Legal entity is required to pay the following minimum corporate tax if the reported tax liability falls below the applicable minimum tax threshold determined based on the taxable income:

  • EUR 340 is applicable for taxable income (revenue) less than EUR 50,000.
  • EUR 960 is applicable for taxable income (revenue) ranging from EUR 50,000 to EUR 250,000.
  • EUR 1,920 is applicable for taxable income (revenue) ranging from EUR 250,000 to EUR 500,000
  • EUR 3,840 is applicable for taxable income (revenue) of EUR 500,000 and above.

Only a limited number of exceptions from the payment of the minimum tax are allowed, such as companies in bankruptcy, companies in their initial taxable period, non-profit organizations, etc.

Withholding tax on domestic payments

Withholding tax of 19% is levied on income from participation certificates, certain debentures, vouchers and investment coupons; and interest from bank deposits and current accounts in general. Withholding tax of 7% shall apply to dividends paid out from profits reported for the tax periods beginning no earlier than January 1, 2024 by domestic companies to individual shareholders. For dividends from profits derived between years 2017 – 2023 the withholding tax rate of 7% is applicable.

With effect from January 1, 2011 the tax withheld is considered to be a final tax rather than an advance payment of tax. The only exemption from this rule applies to income from participation certificates.

Corporate income tax – general information

Residence

A company is treated as resident if it has its legal seat or place of effective management in the Slovak Republic.

Tax period

Calendar year or the business/financial year

Taxable income

Resident companies are taxable on their worldwide income, including capital gains, unless exempted from tax. The taxable income is computed on the basis of the accounting profits and is adjusted for several items as described in the tax law.

Tax returns and assessment

The taxpayer has to calculate the tax due in the corporate income tax return (self-assessment). The deadline for filing the return is by the end of third month following the end of the tax period. The filing deadline may be extended by maximum 3 or 6 months (if part of a taxpayer’s tax base consists of foreign-source income).

Tax advancement

Quarterly, if tax paid for previous year was between EUR 5,000 – EUR 16,600. Monthly, if tax paid for previous year was higher than EUR 16,600. A new business entity established during the tax year (except if it is established by conversion, merger or division) is not required to make advance tax payments.

Deductions

As a general rule, expenses incurred in obtaining, ensuring and maintaining taxable income are fully deductible, unless they are listed as non-deductible items or items which are deductible only up to a limit set by the law.

Carry-forward of losses

Tax losses derived from January 1, 2014 to December 31, 2019 may be carried forward uniformly for 4 tax years. Tax losses derived before 2014 cannot be carried-forward anymore.

With respect to tax loss reported for the tax period beginning no earlier than January 1st, 2020, new rules apply. The condition of equality of tax loss deduction shall not apply anymore and at the same time, the period for its deduction is extended from 4 years to 5 years. However, during the tax period, tax loss deduction of up to 50% of the tax base will be possible only, unless the taxpayer meets the definition of a “micro-taxpayer”.

Intercompany dividends

Dividends paid out of profits derived from January 1st, 2004 are not subject to any tax in the hands of the shareholders. Dividends paid out of profits derived before January 1, 2004 are taxed at the standard 21% corporate income tax rate, if distributed after December 31, 2013. If conditions for reduced corporate income tax rate of 15% (which was introduced since January 1, 2020) are met, then reduced rate shall apply.

Special taxes on corporate income

Regulated industries

(energy, insurance and reinsurance, public health insurance, electronic communications, pharmaceutics, postal services, rail traffic, public water and sewer systems, air transport and health care services under special legislation)

With effect starting September 1, 2012 a temporary special contribution applies. The special duty has to be paid, even after 2016, despite the fact that it should be effective only until the end of that year.

The definition of the taxable base for special duty was amended with effect from January 1, 2017 so that the duty applies only if the accounting result of at least EUR 3 million is reached and only on income from regulated activities.

The monthly rate was temporarily increased to 0.726% for the period from 2017 to 2018. Then the rate started gradually decreased. In the period from 2019 to 2020 the monthly rate was 0.545% and from the period 2021 the rate is again 0.363% (with the exception of banks, which have temporarily established a different rate according to the next point).

Banks

With effect from January 1, 2024, Slovak banks and branches of foreign banks operating in the Slovak Republic, established according to special legislation on banks, are subject to a bank levy. The special bank levy was already effective from 2012 to 2020, but the calculation method differed.

The rate of the special bank levy is set to gradually decrease, with a 2.5% rate applicable for the year 2024. The levy’s base is the accounting result for the respective accounting period multiplied by the coefficient, representing the ratio of revenues from regulated activities to total revenues.. Based on amendment of the law, the special bank levy’s tax rates for future periods will be as follows:

  • For the period 2025, the rate is 2.08 %.
  • For the period 2026, the rate is 1.67 %.
  • For the period 2027, the rate is 1.25 %.
  • For the period 2028 and beyond, the rate is 0.363 %.

Insurance companies

Special levy on all forms of non-life insurance for insurance companies operating in Slovakia was introduced from 2017. 8% is the levy from the received insurance premiums, effective as of January 1, 2017.

According to the law effective until December 31, 2018, levy concerns only the agreements concluded after January 1, 2017. Starting from January 1, 2019, there is a new legislation according to which the special levy will apply on all insurance agreements, regardless the date of the concluding of the agreement, if the insurance period starts to lapse after December 31, 2018.

Generally, the person liable to pay the Insurance Premium Tax shall be the insurance company, however, this obligation may concern also to policyholder (any person who concluded the agreement with the insurer), if this person pays the premium to a third-country insurance undertaking, which does not have a branch in the territory of the Slovak republic or to a legal person to which the costs of such insurance are recharged.

For further details, please see our eBook on tax on non-life insurance premium from January 1, 2019.

Special Solidarity Contribution for Fossil Fuel Companies

In December 2022, new law introducing a new solidarity contribution levy for companies operating in the oil, gas, coal and refinery sectors was adopted.

The solidarity contribution is imposed on both companies that are tax residents of Slovakia and permanent establishments of foreign taxpayers in Slovakia operating in the sectors of extraction of different types of coal as well as gas and crude oil and its processing. These taxpayers are required to pay the solidarity contribution at a rate of 70% with reference to the base, which is the same as the tax base for corporate income tax purposes for tax period, which began in 2022 and ended in 2024.

The solidarity contribution shall be subject to self-assessment and shall be paid within period for corporate income tax return filing. Payment by quarterly instalments is possible. The application of this law was initially intended only for the period 2023, but it was subsequently extended to include the year 2024 as well.

Incentives

Corporate income tax relief can be provided under the Law on Investment Incentives. Certain corporate income tax relief can be provided also under the Law on Research and Development Incentives. The relief is subject to approval of the Ministry of Economy or Ministry of Finance, as the case may be. If a taxpayer does not claim corporate income tax relief under the Law on Research and Development Incentives, a special regime for research and development expenses, introduced with effect from January 1, 2015, can be claimed if certain conditions are fulfilled.

In addition to the above mentioned, a special scheme was introduced with effect from January 1, 2018 for companies having income from commercial use of intangible assets (e.g. registered patents, software) developed by themselves or of so called embedded intangible assets (e.g. income from sale of products in which registered patent developed by the taxpayer is used). Such income shall be exempted up to 50% during the period of amortization of such intangible asset provided certain conditions are met.

For employers involved in vocational training of students, specific tax incentives were introduced with effect as of September 1, 2015.

Further, as from January 1, 2022, a new temporary measure in the form of an additional deduction for investments with higher added value (Industry 4.0) was introduced. The company will be able to reduce the tax base by an additional amount determined with reference to the tax depreciation of invested assets, depending on the fulfilment of the conditions defined in the Income Tax Act up to 55% of the tax depreciation. Since it is a temporary measure, it can only be used for an investment plan that will last in the tax periods 2022 – 2025. The total value of the investment must be more than seven times the average annual investment over the last three years and at least EUR 1 million. The deduction can be applied during the depreciation period, but no more than 10 consecutive tax periods.

International aspects

Resident companies

Foreign income and capital gains

Resident companies are subject to tax on their worldwide income and capital gains. Taxable amount is generally calculated in the same way as in the case of domestic income.

Foreign losses

Losses of foreign permanent establishment (calculated based on Slovak tax rules) may be offset against domestic profits unless, on the basis of an applicable double tax treaty, the exemption method applies for double tax relief.

Dividend income paid by non-resident company

Dividends paid out of profits generated starting January 1,2004 until December 31, 2016 are not subject to any Slovak tax. Dividends paid out of profits generated before January 1, 2004 are included in the taxable base of the recipient and taxed at a standard tax rate of 21% (or from 2020 at reduced rate of 15% if applicable) unless rules implementing EU Parent-Subsidiary Directive applies. Dividends paid out of profits generated from January 1, 2017 shall be included to a separate tax base and taxable at 35% tax rate; this applies only if the distributing company is based in a non-cooperating state, otherwise exemption applies.

Double taxation relief

No unilateral double taxation relief is provided. Double taxation is relieved only on the basis of tax treaties.

Non-resident companies

Taxable income

Non-resident companies are taxed only on income derived from Slovak sources. They are generally taxed according to the rules applicable to residents. Income attributable to a Slovak permanent establishment is generally taxed at 21% rate through a tax return (self-assessment). Since 2020, the reduced rate of 15% applies instead of 21%, if specific income threshold conditions are met.

Withholding tax

Generally, 19% withholding tax or tax security is levied (unless limited under a tax treaty); an increased tax rate of 35% applies if the recipient is a resident of a non-cooperating state (i.e. a state not on the “white list” published by the Slovak Ministry of Finance). For interest and royalty payments EU Interest and Royalties Directive was implemented.

Dividend paid by resident companies to non-resident

There is no withholding tax on dividends paid to non-resident companies out of profits derived by the distributing company as from January 1, 2004 until December 31, 2016. Dividends paid out of profits generated before January 1, 2004 are (unless rules implementing EU Parent-Subsidiary Directive apply) subject to a 19% final withholding tax, unless a reduced rate applies under a tax treaty. Dividends paid out of profits generated from January 1, 2017 shall be subject to a 35% withholding tax however only if the recipients are foreign companies based in non-cooperating state.

Anti-avoidance rules

Thin capitalization

Applicable on interest expenses arising in the tax period starting January 1, 2015. All resident legal entities and non-resident legal entities having a permanent establishment in Slovak Republic are covered, with the exception of financial institutions, leasing companies and subjects of collective investments. The deduction of interest expenses (including of other related expenses) on loans from related parties exceeding 25% of a company’s earnings before interest, taxes, depreciation, and amortization is prohibited.

Other interest limitation rules

By transposing Article 4 of the Council Directive (EU) 2016/1164 laying down rules against tax avoidance practices that directly affect the functioning of the internal market (this Directive is further referred to as “ATAD”) to the Slovak Income Tax Act in 2022, an additional rule on the limitation of interest costs in relation to creditors is introduced, which is effective from January 1, 2024. All resident legal entities and non-resident legal entities having a permanent establishment in Slovak Republic are covered, with the exception of some specific companies (e.g., financial institutions, financial agents, subjects of collective investments).

According to that rule, if the amount of net interest costs is higher than EUR 3,000,000, the tax base will increase by the amount by which the net interest costs exceed 30% of tax EBITDA. For those purposes, all interest costs and revenues are considered, not only toward the related parties. Moreover, interest costs will be interpreted broadly.

This rule takes precedence over the thin capitalization rule. This means that if conditions for application of this new rule are met, the thin capitalization rules shall not be tested from 2024.

This new rule applies for the first time to net interest costs arising on the basis of contracts concluded after December 31, 2023, including amendments concluded after December 31, 2023.

Transfer pricing

With effect starting January 1, 2015, the transfer pricing rules apply also between resident related parties. Until December 31, 2014, transfer pricing rules applied only to transactions concluded by residents with foreign related parties.

Mandatory transfer pricing documentation requirements exist, which generally follow the recommendations contained in the OECD Guidelines on Transfer Pricing and the EU Code of Conduct on Transfer Pricing Documentation. For more detailed information read also our Transfer Pricing Overview for Slovakia.

Hybrid mismatches

As a result of the implementation of the ATAD, the rules on hybrid mismatches were introduced in the national income tax law with effect from January 1, 2018. The aim of these rules is to prevent a situation between related parties that leads to double deduction or deduction without inclusion. Later on, with effect from January 1, 2020, measures implementing the Council Directive (EU) 2017/952 (i.e., “ATAD 2”) were introduced in the national tax law, while measures implementing Article 9a of that directive were adopted with effective date January 1, 2022. This directive aims to prevent the use of hybrid elements as a result of different tax assessments of financial instruments and taxpayers, particularly in the international context, leading to reduction of the tax liabilities.

Exit tax

Introduction of rules on exit tax with effect from January 1, 2018 was part of the implementation of the ATAD, too. Exit tax at rate of21%shall applyto legal personsin the case of taxpayer’s property transfer, taxpayer’s leaving or transfer of their business abroad.

In the case of taxpayer’s property transfer, taxpayer’s leaving or transfer of their business abroad. In the case of taxation, the fiction of a property sale, or sale of the enterprise or its part should apply.  The aim of taxation is to ensure that in the case of taxpayer’s property transfer or changing tax residence abroad, the taxpayer will tax an economic value of all capital gains earned in Slovakia, even though this gain is not realized in the moment of leaving.

Controlled foreign company

In 2017, when implementing the ATAD, the CFC legislation was approved, as well, and this with effect from January 1, 2019.

The CFC rules consist of assigning the income of a low-taxed controlled subsidiary company to its parent company. Part of the parent company’s tax base will be the income of controlled foreign company to the extent to which the assets and risks are attributable to that income that are connected to main functions of the parent company.

As a controlled foreign company shall be treated the company or subject:

in which the tax resident company by itself or together with associated enterprises has the holding of more than 50% or

the proportion of the voting rights of more than 50% or

profit-shares of more than 50%.

Concurrently, the corporate income tax paid by the controlled foreign company abroad is lower than 50% of the corporate income tax that the controlled foreign company would pay in the Slovak Republic after the tax base has been calculated in accordance with the Slovak law.

As the controlled foreign company is considered also the permanent establishment, while the first condition is not examined in this case.

Global minimal taxation

With effective date on December 31, 2023, an adaptation of Council Directive (EU) 2022/2523 were introduced in the national tax law through the new law on the so-called top-up tax, to ensure a global minimal level of taxation for multinational enterprise groups and large-scale domestic groups.

The top-up tax will apply to companies located in the European Union, that are members of multinational groups or large domestic groups with yearly consolidated revenues more than EUR 750 million in two out of four tax periods.

All members of these groups in the Slovak Republic, must lasting from 2024, monitor their effective tax rate to achieve at least 15%. Otherwise, there will be an obligation to calculate the additional tax (top-up tax) as the difference between the actual effective tax rate of the respective group members and the 15% effective tax rate. Monitoring and possible calculation of top-up tax must be carried out jointly at the level of all members located in the Slovak Republic belonging to the same group.

The effective tax rate = Taxes* / Accounting result adjusted for items specified in the law

*Taxes including mainly due and deferred corporate income tax, withholding tax, special contributions

There are also set up some exemptions from the calculation of the top-up tax, basically for groups which do business in Slovakia through smaller entities and met the specific conditions set up by law. Some of the conditions are only temporary (applicable for accounting periods 2024 – 2026).

Public entities, international organizations, non-profit organizations, pension funds and investments funds that are main parent entities are excluded from the application of top-up tax.

The entity qualified for top-up tax application will be obliged to submit a notification with the information necessary for the calculation of the top-up tax, together with the tax return, within 15 months after the end of the relevant tax period. For the first tax period, which is 2024 (for entities applying calendar year), the deadline is extended by three calendar months (i.e. until the end of June 2023).

The members of the same group from the Slovak Republic might agree on the fulfillment of their obligations by only one of them, or under certain circumstances, by the main parent company.

Taxes on individual income

Personal income tax – rates

The tax rates applicable for income derived in 2023 are:

  • annual taxable income (except for income from business activity, capital and dividend income) up to EUR 47,537.98 is taxed at 19%
  • annual taxable income (except for income from business activity, capital and dividend income) above EUR 47,537.98 is taxed at 25%
  • income from business activity is taxed at reduced tax rate of 15%, if its annual taxable value does not exceed EUR 60,000 (note: in 2020 the threshold was EUR 100,000; between 2021 – 2023 the threshold was EUR 49,790); otherwise, 19% rate applies for taxable business income up to EUR 47,537.98 and 25% rate applies to the amount, which is above that threshold

Income from capital is taxed at flat rate of 19%. Income from dividends paid out of pre-2004 profits and profits derived from January 1, 2017 to December 31, 2023 is taxed at 7% (35% applies if dividends are from foreign sources of non-cooperating state). For income from dividends derived from profits for periods starting after January 1, 2024, a tax rate of 10% applies (while the rate of 35% still applies for dividends from foreign sources of non-cooperating states).

Moreover, an additional tax of 5% is to be paid by the representatives of constitutional bodies (e.g. the President, Members of Parliament) on their employment income. Certain types of income are not aggregated but are subject to a final withholding tax of 19% or of 7% resp. 10% in the case of dividends paid out by domestic company.

Personal income tax – general information

Residence

Individuals who have their permanent residence or habitual abode in Slovakia are treated as residents. An individual has his habitual abode in Slovakia if they are present in Slovakia for at least 183 days (in aggregate) in a calendar year (except individuals who stay there for the purposes of studying or receiving medical treatment).

Starting from January 1, 2018, in addition to the above two mentioned criteria also the criterion of a real residence shall be examined. If an individual is provided with permanent accommodation on the territory of the Slovak Republic that does not only serve for occasional accommodation due to short-term visits, they will be treated as a resident, as well.

All other individuals are treated as non-residents.

Taxable income

Individuals who are residents for tax purposes in Slovakia are taxable on their worldwide income. Taxable income of an individual is usually calculated by aggregating the separate net results of the following income categories:

employment income

rental income and income from the use of work and art performance

other income (e.g. income from occasional activities)

Starting January 1, 2016 income from capital is not aggregated but separate tax base is to be calculated on that income. Also, dividend income is subject to a separate tax base as of January 1, 2017. Starting with January 1, 2020, income from business activities and other independent professional activities is not aggregated, too and separate tax base shall be calculated on that income.

Specific exemptions and deductions apply for the purposes of determining the net result of each income category.

Dividends paid out of 2004 – 2016 profits are not subject to any tax.

Tax assessment

Taxpayers deriving income that is not taxed through a withholding tax or are exempt have to file an income tax return by March 31st in the year following the tax year (self-assessment). The filling period may be extended upon certain conditions.

Taxpayers whose annual income does not exceed 50% of the amount of the basic allowance have to file a tax return only if losses are declared. Taxpayers having income only from a single employment are not required to file a tax return, if certain conditions are met.

Losses

Tax losses generated from business activities and other independent professional activities may only be set off against income derived from those types of activity. Losses that cannot be set off may be carried forward. The standard carry-forward period for pre-2020 tax losses is 4 years, and the losses must be carried forward evenly. With respect to tax loss reported for the tax period beginning on January 1, 2020 or later, new rules apply. The condition of equality of tax loss deduction shall not apply anymore and at the same time, the period for its deduction is extended from 4 years to 5 years. However, in the tax period, tax loss deduction of up to 50% of the business activity income tax base will be possible only, unless the taxpayer meets the definition of a “micro-taxpayer”.

Personal deductions

Supplementary pension insurance contributions may be deducted up to EUR 180 per year if certain conditions are met.

From January 1, 2021, specific deductions with respect to expenses paid by individuals for services of spa resorts that have licence pursuant to special legislation, cannot be claimed any more.

Personal deductions can be claimed only with respect to active income (income from employment, business activities and other independent gainful activities). Starting with January 1, 2020, these deductions shall be claimed primarily with respect to taxable employment income.

Advance payments

Individuals who conduct business activities other than those whose last known tax liability was EUR 5,000 or less are required to pay advance payments (quarterly or monthly as the case may be).

In the case of employment income, the employer is obliged to remit the tax to the tax authorities no later than on the fifth day after the wages were paid.

Allowances

Basic personal allowances

Basic personal allowance can be claimed only with respect to active income (income from employment, business activities and other independent gainful activities). Starting with January 1st, 2020, basic personal allowances shall be claimed primarily with respect to taxable employment income. If taxable employment income is lower than is the amount of basic allowances, then the difference can be claimed with respect to taxable income from business activities and other independent gainful activities.

In 2024, the following annual basic personal allowances can be claimed:

  • EUR 5,646.48 (21 times the living minimum*) if the aggregate annual net active income is up to EUR 24,952.06; and
  • EUR 11,884.50 (44.2 times the living minimum*) less one fourth of the aggregate annual net income if the aggregate annual net income is higher than EUR 24,952.06. If the result is negative (i.e. if the aggregate annual net income exceeds EUR 47,537.98), the basic personal allowance cannot be claimed.

* The living minimum applicable on January 1st of the tax year (EUR 268,88 for 2024)

Dependent–spouse allowance

It can be claimed only with respect to active income (income from employment, business activities and other independent gainful activities). Starting with January 1, 2020, it shall be claimed primarily with respect to taxable employment income.

In 2024, allowance of up toEUR 5,162.50 can be claimed by a resident taxpayer whose spouse does not have annual taxable income and if the aggregated net active income of that taxpayer does not exceed EUR 47,537.98. If a spouse earns less than EUR 5,162.50, this allowance is calculated as the difference between EUR 5,162.50 and the spouse’s actual income. If the taxpayer’s annual net active income exceeds EUR 47,537.98, the allowance is gradually reduced to null, such that those whose annual income exceeds EUR 68,187.96 are not entitled to the allowance.

Credits

Resident taxpayers having taxable employment or business income are entitled to a tax credit for each dependent child living in the same household with him.  As from July 1, 2022, the condition of required minimum amount of active income, was cancelled. In 2024, a credit of:

  • EUR 140 can be claimed per child per month with respect to children up to 18 years old;
  • EUR 50 can be claimed with respect to children older than 18.

If there is a specific meal allowance provided for a child up to 18 years old, there is no entitlement for a tax credit.

At the same time, the maximum amounts of tax credit were introduced, which depend on the number of children living in the same household. In 2024, they are as follows:

Number of dependent children Maximum amount of tax credit (% from tax base from active income)
1 20
2 27
3 34
4 41
5 48
6 and more 55

Tax credit on interest paid

Starting from January 1, 2018, the taxpayers are entitled also to a tax credit in the case they pay interests on a mortgage and certain conditions are met. Tax credit can be in the amount of 50% of paid interests in given tax period, up to EUR 400 per year. The amount of interest shall be calculated at maximum from EUR 50,000 per one domestic dwelling.

Starting from January 1, 2024, the tax credit on interest paid on a mortgage increased to 50% of paid interests during five years, up to EUR 1,200 (previously EUR 400) per year. Increased amount of tax credit can be claimed by individuals if certain conditions are met i.e., individuals aged between 18 and 35, who concluded new mortgage agreement after 1.1.2024; whose average monthly income is up to 1.6 times the average monthly salary of employees in the economy; no limit of the amount of mortgage (previously up EUR 50,000); the property should be for living purpose and cannot be rented.

Tax credit on increased mortgage instalment

Individuals who refixed their mortgage can apply a tax credit on an increased mortgage instalment for the year 2023. Individuals who earn up to 1.6 times the average monthly salary of employees in the economy are entitled to the tax credit equal to 75% of the difference between the original and the increased monthly instalment at the same bank, up to EUR 150 per month (up to EUR 1,800 per year). For 2023, the individuals may opt whether they apply the tax credit on interest paid or tax credit on increased mortgage instalment. For 2024, individuals can only apply for the contribution on increased mortgage instalment at local labour offices.

International aspects

Resident individuals

Foreign source income

Resident individuals are subject to tax on their worldwide income. Taxable amount is generally calculated in the same way as in the case of domestic income.

Dividend income

Foreign dividends are generally exempt if paid from profits derived by the distributing company starting January 1, 2004 until December 31, 2016. Dividends paid out of pre-2004 profits and dividends from profits derived from January 1, 2017 to December 31, 2023 are taxable at 7%, or at 10% if profits derived from periods starting from January 1, 2024, If dividends are from foreign sources of non-cooperating state, the applicable tax rate increases up to 35%.

Double taxation relief

Income earned from employment performed abroad is exempt in Slovakia if the taxpayer can prove that such income has been taxed abroad. There is no other unilateral double taxation relief, but relief may be obtained under a tax treaty.

CFC rules to natural persons

The rules for controlled foreign companies (CFC) were applicable also to natural persons only for limited time period, lasing from January 1, 2022 (the original proposal was from January 1, 2021) until July 31, 2023. For this limited time period, CFC rules for natural persons in Slovakia set out that the profit shares (dividends) in a CFC company shall be taxed at the moment of their potential claim of a natural person’s taxpayer and not when they are paid. Income shall be allocated from the economic result as reported abroad.

The CFC means a legal entity or another entity with a corporate seat abroad, if the following conditions are met:

natural person alone or together with related persons has a direct, indirect or indirect derived share in the capital, voting rights or has the right to share in the profit of at least 10%, or has real control over this company and

the controlled foreign company is a taxpayer of a non-cooperating state or is a non-taxpayer of a non-cooperating country, but the effective taxation of income is less than 10%.

Income taxation shall be through a separate tax base, at 25 % or 35 % for non-cooperating countries.  From August 1, 2023, all rules on controlled foreign companies for natural persons have been removed from tax legislative.

Non-resident individuals

Taxable income

Non-resident individuals are taxed only on their income derived from Slovak sources. Employment income derived by non-residents from employment performed in Slovakia for a period not exceeding 183 days in 12 consecutive months is exempt. The exemption does not apply to activities performed by artists or sportsmen, or through a permanent establishment. The income of non-residents is generally taxed according to the rules applicable to residents unless a law or a tax treaty provides otherwise.

Personal allowances

Non-residents are entitled to the basic personal allowance (see above). In case their income from Slovak sources in the tax year is at least 90% of their total income, they are entitled also to the dependent-spouse allowance and tax credits.

Withholding tax

Generally, 19% withholding tax or tax security is levied (unless limited under a tax treaty); an increased tax rate of 35% applies if the recipient is a resident of a non-cooperating state.

Dividend income

There is no withholding tax on dividends paid to non-resident individuals for 2004 – 2016 profits. Unless otherwise stated in the treaty, dividends from profits derived from January 1, 2017 to December 31, 2023 are subject to withholding tax of 7%, or withholding tax of 10% for profits derived from periods starting from January 1, 2024. If dividends are from foreign sources of non-cooperating state, the applicable withholding tax rate increases to 35%, unless otherwise stated in the treaty.

Value added tax (VAT)

Value-added tax – rates

  • Standard rate: 20%
  • Reduced rate: 10% or 5%.

Export of goods and services is zero rated.

Intra-Community supplies of goods are zero rated under certain conditions.

Value-added tax – general information

Legislation

The VAT rules are based on the principles of the Council Directive 2006/112/EC on the Common System of Value-Added Tax.

Taxable person

Legal entities and individuals that carry on an economic activity.

Taxable event:

  • the supply of goods and services for consideration within the territory of Slovakia by taxable persons acting as such
  • the intra-Community acquisition of goods for consideration within the territory of the Slovakia from another EU Member State
  • the importation of goods into Slovakia

Taxable amount

Total consideration charged for the supply, excluding VAT but including any excise duties or other taxes and fees.

Tax period

Tax period for VAT is month or quarter, based on turnover for 12 previous consecutive calendar months. Compulsory tax period for new registered VAT payers is calendar month.

Tax assessment

Periodical VAT returns: monthly or quarterly, by the 25th day of the following month.

The amount of VAT liability consists of the VAT due on supply of goods and services carried out by the entrepreneur less input VAT of the same period. In addition, taxable person carrying out intra-Community supplies or supplying services according to the basic rule for “business to business” services have to file an EC Sales List (that shows the VAT identification numbers of his business partners and the total value of all the supplies of goods and services performed by the entrepreneur) on a monthly or quarterly basis depending on the situation.

VAT ledger statement

From 2014, VAT registered persons are also obliged to file a recapitulative statement that contain details of transactions subject to VAT in Slovakia as well as of transactions where input VAT deduction is claimed.

VAT registration

The threshold for mandatory VAT registration for taxable person with registered office, place of business or fixed establishment in Slovakia is turnover of EUR 49,790 for a period of 12 previous consecutive calendar months. Taxable persons supplying real property (buildings, building land) have to register for VAT purposes if certain conditions are met. The voluntary VAT registration is possible as well.

Starting from January 1, 2023, domestic taxable persons who perform exclusively exempted activities such as financial, insurance services, delivery and rental of real estate are allowed to voluntarily decide whether to register for VAT purposes after the turnover threshold has been reached.

In case of intra-community acquisition of goods from another EU-Member state, the taxable person not registered for VAT has to register for VAT before the value of those transactions cumulative exceeds EUR 14,000 in calendar year.

A taxable person (not registered as a VAT payer) has to register and pay output VAT or to report the supply of service in EC Sales List if the place of delivery for that service is:

  • following the Article 44 of the Directive 2006/112/EC
  • located in another EU-Member state as is the EU-Member state of supplier of that service
  • person duty to tax will be the recipient of that service

VAT registration is mandatory for foreign taxable persons without registered office or fixed establishment in Slovakia before it carries out activity which is subject to VAT in Slovakia and „reverse charge” mechanism is not applied. In the field of e-commerce and optional one stop shop schemes, as from July 1, 2021, the rules implementing the Council Directive (EU) 2017/2455 and Council Directive (EU) 2019/1995 entered into force.

VAT group registration

Several taxable persons who have their seat, place of business or fixed establishment within the territory of the Slovak Republic and are connected financially, economically and organizationally, may be deemed as a single taxable person.

Extra notification duties of bank accounts

Starting from November 15, 2021, a special notification obligation for VAT payers applies, for each bank account used for business purposes. All registered VAT payers are obliged to report the numbers of all own bank accounts (payment, deposit), which the VAT payer will use for business that is a subject to tax under the Slovak VAT Act. This obligation applies both to bank accounts held with a domestic payment service provider and to accounts held with foreign payment service providers.

Newly registered VAT payers will be required to comply with the reporting obligation immediately from the date on which they became VAT payers or immediately from the date on which they set up such an account after they have been registered as VAT payers by the tax office.

VAT payers will be obliged to also notify any subsequent change, addition, or cancellation of notified bank accounts without delay.

The purpose of this measure is to publish, starting from January 1, 2022, the list of VAT payers’ bank accounts on the website of the Financial Directorate on a daily basis. Payment of the supplier’s invoice to a bank account which was not listed at the time of payment may lead to the application of the tax guaranteeing institute. Therefore, customers should pay increased attention to the supplier’s bank accounts, to which they will make the payment of invoices. It also applies that tax office return the excess deduction only to one of the bank accounts notified to it by the VAT payer as part of the mentioned special notification obligation.

Extra notification duties of payment service providers

Following the transposition of the Council Directive (EU) 2020/284 into Slovak VAT legislation with effect from January 1, 2024, the payment service providers have new notification duty starting from January 1, 2024.

Domestic payment service providers are required to keep records of payees and cross-border payments in connection with the payment services they provide for each calendar quarter (25 cross-border payments or more to a single recipient), and at the same time to make these records available to the Financial Directorate of the Slovak Republic. Payment service providers shall retain relevant data, submit it to the tax authorities upon crossing the threshold by using a standardized electronic form (uniform across the entire EU) no later than till the end of the month following the relevant calendar quarter to which the information pertains. These records shall be sent by each member state to the Central European Payment System (so-called CESOP), where they are cross-checked and evaluated.

The aim of this is to combat tax avoidance in the field of cross-border e-commerce, as well as to check the correctness of the amount of tax declared. Read more information about legislative changes in the area of VAT effective from 2024 in our article.

Other taxes

Taxes on capital

Net worth tax – There is no net worth tax in Slovakia.

Real estate tax

This tax consists of land tax, building tax and apartment tax. The general rate of the land tax is 0.25% of the value. The general rate of the building tax and the apartment tax is EUR 0.033 per m2. The municipalities may increase or decrease these rates in accordance with local conditions.

Other business-related taxes

Motor vehicle tax

Levied on motor vehicles and trailers in categories L, M, N, and O if registered in Slovak republic and used for business purposes.

Excise duties

Excise duties are levied on mineral oil, beer, wine, spirits, electricity, coal, natural gas and tobacco products.

Customs duties

Goods imported from non-EU countries are subject to import customs clearance.

Transfer pricing is a topic discussed with increasing frequency not only in the world, but also in Slovakia, where the amount of tax  inspections mainly in the given field rises on a yearly basis. The importance of preparing the transfer pricing documentation in Slovakia has increased also in regards to the Slovak legislation, which applies the obligation to prepare the documentation not only to foreign related parties but to domestic related parties as well. In practice, it means that if you are a statutory representative of two different Slovak companies, you can not perform transactions between the related companies for tax purposes in arbitrary prices, but only in amounts that would be agreed on between two independent parties under comparable conditions. Otherwise you may be penalized by sanctions. The method applied for setting the prices has to be in accordance to the Slovak tax legislation.

Considering the increasing importance of this field, we prepared a comprehensive eBook 2024 Transfer Pricing Overview for Slovakia, where you can read not only about all the important information regarding transfer pricing, but also about the content of necessary transfer pricing documentations justifying methods used to evaluate transactions between related parties.

Download our 2024 Transfer Pricing Overview for Slovakia or read more below

Applicable legislation

  • Income Tax Act No. 595/2003 Coll. (Sections 2/n-r, 17/5, 17/6, 17/7, 18, 18a)
  • Double Tax Treaties
  • Financial Reporters No. 14/1997, 20/1999, 3/2002 where OECD Transfer Pricing Guidelines from 1995 and 1997 were published in Slovak language
  • Financial Reporters No. 1/2009, 8/2014, 5/2015, 7/2016, 12/2018 where administrative guidance of the Slovak Ministry of Finance on content of the transfer pricing documentation were published

As an OECD Member State and an EU Member State, Slovakia adheres to the OECD Transfer Pricing Guidelines and to the EU Code of Conduct on transfer pricing documentation for associated enterprises. Slovakia also acceded to the EU Arbitration Convention, which establishes a procedure to resolve disputes where double taxation occurs between enterprises of different Member States as a result of an upward adjustment of profits of an enterprise of one Member State.

Arm’s length principle

Applicability

The arm’s length principle is based on a comparison of the terms which were agreed in any business or financial transactions between related parties and the terms which would have been agreed between unrelated parties in similar business or financial transactions, in comparable circumstances.

The review of comparability of the terms is made by confronting in particular the businesses conducted by the parties, including, but not limited to their production, assembly works, research and development, purchase and sale, the scope of their business risks, the characteristics of the compared property or the service, the terms agreed between the parties to the transaction, the economic environment in the marketplace, and the business strategy. The terms shall be considered comparable if there is no difference at all or if only minor adjustments would compensate such a difference.

If there is a difference between the prices agreed in transactions of related parties, and the prices applied between unrelated parties in comparable business transactions, as long as such difference results in a reduction of the tax base or increase of tax loss, the related party shall increase its income tax base by that difference. As from January 1, 2023, the materiality threshold was introduced for controlled transaction (or group of controlled transactions that may be aggregated), for which such tax base adjustment is required. As qualified controlled transaction is considered a legal relationship or other similar relationship in which one or more related parties achieve taxable income or tax-deductible expense exceeding EUR 10,000. In the case of loan transaction, the qualified transaction is with a principal amount above EUR 50,000.

General terms

The term “related party” means – (1) close persons, (2) persons or subjects with economic, personal or other ties, (3) persons or subjects that are members of the consolidated group.* By “close persons” should be understood close persons pursuant to Civil Code.

The term “subject” was introduced in the Slovak Income Tax Act as from January 1st 2018 and shall have the following meaning: „legal structure of assets or legal structure of persons, which does not have a legal personality or any other legal structure, which owns assets or performs asset management“.

By “economic or personal tie” should be understood:

  • the person’s or subject’s interest in the property, control or management of another person or subject, or
  • the mutual relation between persons or subjects who are under control or management of the same person, his/her close person or subject, or
  • where such person, his/her close person or subject has direct or indirect ownership interest

Interest in the “property” or “control” means at least a 25% direct or indirect interest or indirect derived interest in the registered capital or in voting rights or at least a 25% share on profit; where the indirect derived interest exceeds 50%, all persons or subjects used in the calculation thereof shall be deemed to have economic ties irrespective of the actual amount of their interest. Starting from January 1, 2023, this definition is stricter in the meaning that for purposes of calculation of direct interest, indirect interest and indirect derived interest, the interests of close persons (e.g., spouses) shall be tot up.

The term “other ties” means a legal relationship, or any other similar relationship established particularly for the purposes of tax base decrease or tax loss increase.

The term “management” means the relationship between the members of the statutory bodies, the members of the supervisory bodies or the members of some other similar bodies of a legal entity or a subject to that legal entity or subject.

As from January 1, 2023, it is also extended that by economic tie shall be understood along:

  • the relation between tax resident taxpayer and his permanent establishments abroad,
  • the relation between tax non-resident and his permanent establishments in Slovakia,
  • the relation among permanent establishments of taxpayers that are considered as related parties in the sense of the abovementioned, and the relation between such permanent establishment and such taxpayer
  • also the relation among permanent establishments of the taxpayer.

Documentation

Content

The transfer pricing documentation represents a set of information, data and facts which demonstrate and explain the method of taxpayer’s price formation in controlled transactions.

Transfer pricing documentation in general consists of general and of specific part.

The general part contains a set of information giving an overall picture of the group of related parties

The specific part contains specific information related to the taxpayer and to the controlled transactions in which the taxpayer is engaged

General rules

Transfer pricing documentation shall be prepared for each controlled transaction separately or for each group of aggregated controlled transactions.

The documentation should be prepared in Slovak language. However, as from January 1, 2023, it can be filed with the tax administrator also in a foreign language. If the latter occurs, the tax authority may upon request ask for translation to Slovak within 15 days from the delivery of the request.

Transfer pricing documentation shall be kept for the respective tax period. If no new facts occur – facts that would affect the valuation method for controlled transactions, when preparing documentation for the next period – a taxpayer may refer to information stated in documentation for the previous taxation periods.

Deadlines

The taxpayer shall submit the transfer pricing documentation within 15 days from delivery of the tax administration’s or financial directorate’s request. Such request may be for the transfer pricing documentation for the relevant tax period, sent no earlier than on the first day following expiry of the period for tax return filing for that particular tax period. Due to short 15-day period it is recommended having the documentation prepared in advance.

Documentation types

There are three different types of transfer pricing documentation in terms of the required minimum scope:

Complete documentation

Basic documentation (simplified documentation)

Shortened documentation (extra simplified documentation)

Obligation to keep the documentation

Starting with the tax period, which begins after December 31, 2017, complete documentation has to be kept by the following taxpayers:

  • taxpayers who follow for statutory purposes the IFRS in booking or closing of booking – the obligation to keep a complete documentation is with respect to significant cross-border controlled transactions;
  • taxpayers that are engaged in the cross-border controlled transaction with value exceeding 10 million EUR per tax period;
  • taxpayers who perform significant business transactions with a related party seated in a state which Slovakia has no double tax treaty or international tax information exchange agreement with;
  • taxpayers who are engaged in the controlled transactions with respect to which they opt for an APA (Advance Pricing Agreement)
  • taxpayers who asks for secondary adjustments for the controlled transaction according to double tax treaties
  • taxpayers who are engaged in the controlled transactions with respect to which there was a request filed for a mutual agreement procedure according to a tax treaty;
  • taxpayers who claim a tax relief – the obligation to keep a complete documentation is with respect to significant cross-border controlled transactions.

In other cases, the taxpayer is obliged to keep a basic documentation for the following transactions:

  • cross-border controlled transactions with annual value exceeding 1 million EUR;
  • non-significant transactions with a related party seated in a state which Slovakia has no double tax treaty or international tax information exchange agreement with;
  • significant cross-border controlled transactions, if the taxpayer’s total operating and financial revenues per tax period exceed 8 million EUR;
  • significant domestic controlled transactions, if the taxpayer claims a tax relief.

If neither complete documentation nor basic documentation is prepared on controlled transaction, taxpayer is obliged to keep on such transaction a shortened documentation (following the template prepared by the Slovak Ministry of Finance), except for some cases, when it is sufficient to properly report controlled transactions in income tax return only.

Also, some Slovak public entities may qualify for keeping of shortened documentation.

In that respect it has to be mentioned that simplified types of documentation may in the listed cases be sufficient from administrative point of view but will not help a taxpayer to prove the application of the arm’s length principle, unless a comparability analysis is made. Therefore, any material transaction from the perspective taxpayer is recommended to be followed by functional and risk analysis and benchmarking.

Methods

Any traditional and other transfer pricing methods according to OECD Transfer Pricing Guidelines can be used while the principle of the best method shall be applied. Also, combination of more methods is possible if necessary. If appropriate, other methods may be used by Slovak taxpayers, too.

Methods based on comparison of prices

Comparable uncontrolled price method – used mainly for transactions with tangible and intangible assets and financial transactions

Cost plus method – used mainly for transactions related to manufacturing and sale of semi- finished products/ finished products which do not include high added value

Resale minus method – used mainly for distributors of products

Methods based on comparison of profits

Net trading margin method – mainly for comparable transactions that significantly differs in functions

Profit split method – suitable for very integrated transactions when the parties contribute in a unique way or they possess valuable tangible asset

Advance Pricing Agreements

Taxpayers in Slovakia can ask the tax authority for an Advance Pricing Agreement (APA) – an approval of a particular method of transfer pricing – at least 60 days before the beginning of the tax period during which the approved method shall apply. By this way they can approve the chosen methodology and avoid potential disputes as far as the method is concerned. Only the method can be approved with the APA, not the used transfer prices itself.

The tax administration shall issue a decision on the approval of the valuation method valid for no more than five tax periods. Extension for next five years is possible if the taxpayer demonstrates that no change has occurred in the conditions upon which the decision was issued.

The fee for applying for the APA as from January 1, 2017 does no longer depend on the value of the business case, but is to be set as follows:

Unilateral APA
10,000 EUR

%
Bilateral and multilateral APA
30,000 EUR

%

From January 1, 2022, the statutory fee is half for a taxpayer who is considered highly reliable at the time of application based on the evaluation of the tax reliability index. For further information regarding the tax reliability index of taxpayers valid from January 1, 2022 please see our News Flash.

The reduced amount of the fee for the APA for highly reliable taxpayers will be applicable only after the first delivery of the notification of the index of tax reliability.

Penalties

For non-compliance with the Transfer Pricing documentation obligations a penalty up to EUR 3,000 for a breach of a non-monetary obligation can be levied. Moreover, the tax base may be adjusted and additional tax may be levied by Slovak tax authorities during the tax inspection.

The tax authority can assess a tax difference up to 10 years after the end of year, in which the obligation to submit a tax return has arisen, i.e. tax return can be a subject of tax inspection for 11 years.

6*ECB rate or 20% p.a. is the penalty rate from the tax difference instead of 10% p.a. or 3*ECB rate (higher rate shall be applicable). As from January 1st, 2017 stricter penalties apply for intentional breach of the arm´s length principle. Doubled penalties will apply to taxpayers who decrease their tax base or increase their tax loss intentionally with the help of Transfer Pricing. 

Affecting both domestic and foreign businesses, a number of actions triggers the obligation to register for VAT in Slovakia. To provide a basic overview, our Slovak experts prepared a comprehensive eBook on value-added tax in Slovakia. Find out more about VAT rates, registration of taxable persons, communication with local tax authorities, compliance and VAT return filing, VAT refund to EU member states or third countries and penalties.

Download our free eBook on VAT in Slovakia or read more below

VAT rates

Basic and reduced VAT rates

The basic VAT rate in Slovakia is 20%. 10% is the first reduced rate that is also applicable. 5% is the second reduced rate applicable for limited goods and services.

Although the reduced rate 10 % applies to a longer list that may change, in general, it may be applicable to pharmaceuticals, some medical products, books, dairy or meat products and accommodation. In any case, the actual product or service should be reviewed individually.

Following the special measure, which was adopted at the end of 2022 as a reaction to the crisis on energy market and with the aim to support tourist business, the reduced 10% rate shall apply from January 1, 2023 also to transport of persons by cable cars, ski lifts, access to indoor and outdoor sports facilities, admission to artificial swimming pools and restaurant and hospitality services.

The second reduced rate 5% is applicable from January 1, 2023 on the transactions related to state-supported residential rent.

Export within and outside the European Union

The supply of goods to other EU member states are free from VAT, if delivered to a VAT payer registered in another EU member state and transported to such member state. The export of goods outside of EU is free from VAT but is subject to the confirmation of custom authorities on export from EU.

Taxable amount

The taxable amount equals everything that is deemed to be received or shall be received for the delivery of goods or services. In case of the import of goods from third countries, the taxable amount is based on the value of customs.

VAT registration of domestic taxable persons

Voluntary and obligatory registration

Voluntary VAT registration in Slovakia is possible, but only for a taxable person, i.e. person (natural or legal person) pursuing economic activity. The turnover threshold for obligatory VAT registration is EUR 49,790 within any 12-month period.

The deadline for filing the obligatory VAT registration falls on the 20th day of the calendar month following the calendar month in which the turnover threshold has been reached. In some special situations there is a shorter period applicable.

Starting from January 1, 2023, domestic taxable persons who perform exclusively exempted activities such as financial, insurance services, delivery and rental of real estate are allowed to voluntarily decide whether to register for VAT purposes after the turnover threshold has been reached.

Group registration for taxable entities

In Slovakia, group registration for VAT is possible. Several taxable persons who have their seat, place of business or fixed establishment within the territory of the Slovak Republic and are financially, economically and organizationally connected, may participate in VAT group registration and as such be deemed as a single taxable person for VAT purposes.

Other specifications of the VAT registration

In Slovakia, a taxable person may become a VAT payer by law without previous registration. It may concern cases of real estate sale, business acquisition or part of a business by purchase or otherwise.

Besides the obligatory registration, Slovak taxable persons must register for the purposes of service delivery to other EU member states, or for the purposes of acquiring goods or services from other EU member states. Registration shall be done in advance.

For those taxable persons that perform e-commerce, it would be worth mentioning that as from July 1, 2021, the rules implementing the Council Directive (EU) 2017/2455 and Council Directive (EU) 2019/1995 entered into force. Further details are available here.

VAT registration of foreign taxable persons

Definition of foreign taxable persons

Foreign taxable persons are entities without seat, place of business or fixed establishment located in Slovakia. Otherwise, they are considered as domestic taxable persons, i.e., the same rules are applicable on foreign persons having a fixed establishment in Slovakia as on domestic taxable persons.

Obligatory registration for foreign taxable persons

Foreign subjects in Slovakia are obliged to register for VAT before the commencement of an activity which is subject to VAT.

In the field of e-commerce, as from July 1, 2021, the rules implementing the Council Directive (EU) 2017/2455 and Council Directive (EU) 2019/1995 entered into force.

Communication with authorities

Local statutory representation for VAT

In Slovakia, local representation by a tax advisor is not obligatory.

Foreign persons may need local representation in specific situations.

Statutory language

Only Slovak language may be used for communication with the tax authorities.

Communication with authorities

A taxable person can communicate with the tax authorities in electronic format, via the data box of the tax administrator.

A qualified electronic signature is required for the electronic communication.

VAT compliance and return filing

Tax period and deadline for VAT return filing

In Slovakia, the calendar month is considered as a tax period. A later change to calendar quarter is possible, but it is subject to several conditions.

The VAT return shall be filed till the 25th day following the respective tax period.

EC sales list and other documents

The EC sales list shall be filed till the 25th day following the respective period, which is in general the calendar month. The EC sales list may be filed for a period of calendar quarter if the value of delivered goods to other EU member states does not exceed the threshold of EUR 50,000 within a calendar quarter nor within the 4 previous calendar quarters.

Besides the VAT return, the control statement listing information from issued and received invoices must be filed as well.

Extra notification duties of bank accounts

Starting from November 15, 2021, all registered VAT payers are obliged to report to Slovak tax administrator the numbers of all own bank accounts (payment, deposit), which the VAT payer will use for business that is a subject to tax under the Slovak VAT Act. This obligation applies both to bank accounts held with a domestic payment service provider and to accounts held with foreign payment service providers.

Newly registered VAT payers will be required to comply with the reporting obligation immediately from the date on which they became VAT payers or immediately from the date on which they set up such an account after they have been registered as VAT payers by the tax office.

VAT payers will be obliged to notify also any subsequent change, addition, or cancellation of notified bank accounts without delay.

The purpose of this measure is to publish, starting from January 1, 2022, the list of VAT payers’ bank accounts on the website of the Financial Directorate on a daily basis. Payment of the supplier’s invoice to a bank account which was not listed at the time of payment may lead to the application of the tax guaranteeing institute. Therefore, customers should pay increased attention to the supplier’s bank accounts, to which they will make the payment of invoices.

It also applies that tax office return the excess deduction only to one of the bank accounts notified to it by the VAT payer as part of the mentioned special notification obligation.

Extra notification duties of payment service providers

Following the transposition of the Council Directive (EU) 2020/284 into Slovak VAT legislation with effect from January 1, 2024, the payment service providers has new notification duty starting from January 1, 2024.

Domestic payment service providers are required to keep records of payees and cross-border payments in connection with the payment services they provide for each calendar quarter (25 cross-border payments or more to a single recipient), and at the same time to make these records available to the Financial Directorate of the Slovak Republic. Payment service providers shall retain relevant data, submit it to the tax authorities upon crossing the threshold by using a standardized electronic form (uniform across the entire EU) no later than till the end of the month following the relevant calendar quarter to which the information pertains. These records shall be sent by each member state to the Central European Payment System (so-called CESOP), where they are cross-checked and evaluated.

The aim of this is to combat tax avoidance in the field of cross-border e-commerce, as well as to check the correctness of the amount of tax declared.

VAT refund to EU member states

Minimum amount and applicable period

The value of requested VAT must be at least EUR 50 for the respective calendar year.

The VAT refund may be requested also for shorter periods than a whole calendar year, however such period shall not be shorter than 3 calendar months and the value of VAT must be at least EUR 400.

Value of VAT for shorter periods
400€

%
Value of VAT for the calendar year
50€

%

Deadline and place of filing for VAT refund

The deadline for filing a VAT refund request is September 30 of the subsequent calendar year. The request for VAT refund shall be filed at the local tax authority in the other EU member state. The deadline for VAT return is 10 working days after laps of period for delivery of the decision made on the VAT refund, which may be between 4 to 8 months since filing VAT refund request.

Refund for foreign taxable persons

Upon the fulfilment of specific conditions. VAT refund for a foreign taxable person is possible.

VAT refund to third countries

VAT refund conditions

VAT refund to third countries is possible only upon the fulfilment of specific conditions, including reciprocity.

Minimum amount and applicable period for VAT refund

The value of requested VAT must be at least EUR 50 for the respective calendar year.

The VAT refund may be requested for the whole calendar year or for half calendar year. However, in case of the later, the value of the requested VAT has to exceed EUR 1,000.

Value of VAT for half calendar year
1000€

%
Value of VAT for the calendar year
50€

%

Deadline and place of filing for VAT refund

The deadline for filing a VAT refund request falls on June 30 of the subsequent calendar year. The request for VAT refund shall be filed at the Tax office in Bratislava, Slovakia. The deadline for VAT return is 6 months after filing the refund request.

Penalties for VAT non-compliance

Depending on the nature of breach of the law, penalty for non-compliance can be imposed in form of fine, based on situation and severity, up to EUR 32,000, or in the form of interest, up to 3xECB rate or 10 % p.a. Delay interest for late payment is 4xECB rate or 15 % p.a.

The employment of expats results in a new set of responsibilities for employers, when it comes to fiscal obligations. Our experts from Slovakia have prepared an overview on global mobility and expat tax in Slovakia, to provide a comprehensive overview on tax residency conditions, personal income tax, social security and health insurance contributions or penalties for non-compliance.

Download our expat tax guide for Slovakia, or check out our brief infographic summary below

Overview of key facts related to expat tax in Slovakia

Our local tax, payroll and labour law experts are here to help you – as an expat or an employer – to obtain essential expert advice, so that you can effectively address all the matters related to cross-border mobility in Slovakia and other locations globally.

Tax residency

An individual is considered a Slovak tax resident if:

They have a registered permanent place of residence in Slovakia, including a temporary residence of EU citizen in Slovakia, or they have an actual residence in Slovakia

They stay for 183 days or more in Slovakia, except for purposes of study, medical treatment

Tax rate

Tax rate on income up to EUR 47,537.98
19%

%
Tax rate on income exceeding EUR 47,537.98
25%

%

Tax period

Calendar year

Social security contributions

Rate for the employer
25.2%

%
Rate for the employee
9.4%

%

Health insurance contributions

Rate for the employer
11%

%
Rate for the employee
4%

%

Tax return filing

The tax return is due by March 31 after the end of the tax period. This deadline may be extended by:

Up to 3 calendar months, with written notification

Up to 6 calendar months with income taxable abroad

Penalties related to expat tax in Slovakia

Delayed filing of the tax return: from EUR 30 up to EUR 16,000

Delayed payment of the due tax: 15% p.a. from the value of overdue tax, for a period of maximum 4 years

Delayed or missing registrations at tax authorities: from EUR 60 up to EUR 20,000

Delayed or missing report on monthly salary or withholding tax from salary: from EUR 30, up to EUR 3,000

Penalties related to social security

Delayed report on social security: up to EUR 16,596.96

Delayed payment of the social security contributions: 0.05% of the amount due for each calendar day

Delayed or missing registrations for the purposes of social security: up to EUR 16,596.96

Penalties related to health insurance

Delayed report on health insurance: up to EUR 3,319

Delayed payment of the health insurance contributions: 15% p.a. from the overdue payment

Delayed or missing registrations for the purposes of health insurance: up to EUR 3,319

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