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Transaction tax for foreign entities in Slovakia: When are you liable for taxation? | News Flash

April 25, 2025
This article is also available in
Slovak

As of January 1, 2025, Slovakia has introduced a new Act No. 279/2024 Coll. on the Financial Transaction Tax (FTT), which significantly affects foreign entrepreneurs and companies operating in Slovakia. The first taxation period begins in April 2025 – so it’s time to prepare now.

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What is subject to taxation?

  • Debit financial transactions (even from a foreign account), if related to activity in Slovakia, and
  • Recharged costs paid by a third party on your behalf in connection with activity in Slovakia.

Who is a taxpayer and who is the income payer?

A foreign self-employed person or a foreign legal entity becomes a taxpayer if:

  • They have a bank account with a payment service provider (a bank) in Slovakia, or
  • They conduct business in Slovakia – e.g., through a warehouse, branch, website, employees, or an agent.

Banks are generally the income payers of FTT. So, if a foreign entity has a bank account with a Slovak bank, the bank will automatically withhold and remit the FTT from debit transactions. However, in case of foreign bank accounts and recharged costs, the foreign entity (taxpayer) must calculate and remit the tax themselves.

What qualifies as conducting activity in Slovakia?

Although the law does not define this term explicitly, further guidelines have been provided. Foreign entities should pay attention if they fall under the following categories:

Physical presence of the taxpayer or their employees in Slovakia

A foreign entity becomes an FTT taxpayer if it conducts activity in Slovakia fully or partially through a permanent place or facility. This can be an office, branch, workshop, etc., or a fixed place where services are provided by the taxpayer or his employees. Construction sites, assembly projects, and use of dependent agents also count as places of activity.

Digital presence

A digital platform (software, website or part thereof, mobile apps) located in Slovakia also qualifies as conducting business. This includes systems enabling customers to make payments or conclude contracts. It does not matter if the goods/services are provided to Slovak customers – only the platform’s location in Slovakia matters.

Online marketplace

If the foreign entity operates a service that allows customers to conclude contracts remotely through a platform located in Slovakia, this also qualifies as activity in Slovakia. It does not matter if the goods/services are provided to Slovak customers – only the platform’s location in Slovakia matters.

Insurance risk in Slovakia

If a foreign entity owns insured real estate or vehicles in Slovakia used for business, this also triggers FTT obligations.

Please find below a few examples of business cases in Slovakia and how the tax liability is triggered:

Business case Tax Obligation
Foreign company has office, website, or agent in Slovakia Yes
Foreign company has bank account in Slovakia but only operates abroad Yes
Foreign self-employed people rent property without extra services (e.g., flat rental only) No
Self-employed person has permanent residence abroad, but has Slovak bank account Yes
Foreign company based abroad, with Slovak bank account renders services in Slovakia Yes
Foreign company rents a Slovak website and insured warehouse in Slovakia that ships goods to their customers Yes
Foreign company runs accommodation facility in Slovakia, has only foreign bank account Yes
Foreign company undertakes a construction project in Slovakia Yes
Foreign company employs staff in Slovakia, but has foreign bank account Yes
Foreign company buys goods in Slovakia and exports outside EU or sells within EU outside Slovakia No
Foreign company acquires goods in Slovakia and sells to Slovak customers Yes

What is the tax rate?

  • 0.4% of the debit transaction amount from a Slovak or foreign bank account, up to €40 per transaction.
  • 0.4% of a financial transaction amount related to the taxpayer’s business in Slovakia, recharged by a third party (if documented), up to €40 per transaction.
  • 0.4% of recharged costs related to financial transactions for business in Slovakia (if individual transactions are not documented).

Tax deduction: How to avoid double taxation?

Recharged costs may be taxed twice. However, the law provides for tax deductions to prevent double taxation.

How we can help you:

  • Assess if the new tax applies to you
  • Analyze your transactions
  • Set up the correct tax reporting

If you believe your company might be affected by the financial transaction tax in Slovakia starting 2025 and would like more information, our tax experts are here to help.

Barbora Juhásová
Tax Manager | Accace Slovakia
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