The Ministry of Finance of the Slovak Republic has published the official template of the tax return for the top-up tax (QDMTT rule), including methodological guidance for its completion. The published tax return form represents another step resulting from the implementation of the Pillar II rules in Slovakia.
Following our previous article on the top-up tax, we present an overview of practical changes related to reporting obligations for which all affected entities should prepare
- Who Is Required to File a Tax Return
The reporting obligation in the form of filing a tax return applies to every taxpayer subject to the top-up tax under the Act – i.e. entities that are members of a multinational or domestic group of enterprises with consolidated revenues exceeding EUR 750 million.
As 2026 represents the first period for which a tax return is to be filed (the monitored period for the purposes of the Act is the 2024 tax period), the deadline for filing the tax return is within 15 calendar months.
The deadline for filing the tax return for the 2024 tax period has been automatically extended by three calendar months to 30 June 2026. The tax return must be filed and the tax paid by this date.
- Rules Arising from the Tax Return
Based on the methodological guidance and the tax return template itself, several aspects arise that affect the obligation to file a tax return in specific cases. Below, we summarise particular points to which taxpayers should pay attention.
Status of the Taxpayer
The tax return is filed depending on the status of the taxpayer itself and not on the calculated amount of top-up tax. This means that taxpayers are required to file a tax return even in the following cases:
- the taxpayer applies selected exemptions under the Act for the tax period (e.g. de minimis exemption, CbCR reporting exemption),
- the total resulting top-up tax equals zero.
Individual Filing of the Tax Return
As follows from the adopted legislation, individual taxpayers in Slovakia (either in the position of a constituent entity or a parent entity) that are members of a group file the tax return individually on their own behalf.
An exception applies to a permanent establishment of a foreign entity, for which the top-up tax return in Slovakia is filed by its founder.
- Structure of the Tax Return
Based on the published template of the tax return form, we recommend that taxpayers focus on the following areas when completing the tax return:
| Area | Required Information |
| Relationship of the taxpayer to the group | This section contains information about the multinational or domestic group of enterprises, including identification of the ultimate parent entity |
| Information is provided about the entity within the group that fulfils the reporting obligations | |
| Application of exemptions | This section indicates the type of exemption from the Pillar II rules applied by the taxpayer. |
| Calculation of the top-up tax | This represents the most important section containing the top-up tax calculations, including: » the reporting currency and the total amount of top-up tax for constituent entities in Slovakia » qualified income or loss at the level of the taxpayer » total income of constituent entities » final amount and payable amount (including conversion into EUR) |
Currently, the template of the notification relating to the top-up tax has not yet been published. We will continue to monitor developments in this area, as we expect the tax authorities to focus on:
- compliance with reporting obligations
- consistency of data between the notification (filed by one entity) and the tax return (filed individually by each entity)
- correct determination of the status of entities within the group
All official forms and guidance are available on the website of the Ministry of Finance of the Slovak Republic in the Financial Bulletin section. The tax return template is available via the relevant link, and the methodological guidance is available in its full wording via the respective link (available in Slovak language only).
