Transfer pricing under close scrutiny by the financial administration: 15 out of 16 audits resulted in findings

he Financial Administration of the Slovak Republic published the results of tax audits conducted by the Office for Selected Economic Entities (OSEE) in the first half of 2026. The OSEE completed 16 corporate income tax audits focused on transfer pricing, of which 15 – i.e. 93.75% – resulted in findings. The cumulative amount of the…

Reducing the administrative burden of corporate sustainability reporting

The Ministry of Finance of the Slovak Republic is preparing amendments to the Accounting Act and the Statutory Audit Act in response to the supplementary transposition of an EU Directive, which reduces the requirements for corporate sustainability reporting and certain corporate sustainability due diligence requirements. Following an assessment of the significant administrative burden associated with…

Abolition of the Ban on Company Chains Simplifies the Creation of Holding Structures

From 17 August 2026, the prohibition on company chains will be removed from the Commercial Code. Since 2002, this prohibition has restricted the ownership structure of limited liability companies. The original purpose of this regulation was to prevent improper chains of single-member companies. However, in practice, this restriction proved ineffective and easy to circumvent. For…

Expansion of the List of Jurisdictions Participating in the Exchange of Information under the GIR MCAA

The OECD has recently published an update on the exchange of information for the purposes of the global minimum tax between the competent tax authorities of jurisdictions that are parties to the Multilateral Competent Authority Agreement on the Exchange of GloBE Information Returns (GIR MCAA). This agreement supports the implementation of the Pillar Two framework.…

Guidance on Withholding Tax on Software Payments

The Ministry of Finance of the Slovak Republic issued new and important guidance to ensure a uniform approach when assessing the taxation of income of non-resident taxpayers from computer software. This methodological guidance introduces a significant change in the assessment and taxation of software payments made by Slovak payers to foreign taxpayers. Below we summarise…