The Financial Administration of the Slovak Republic has published information on the extension of ex officio registration for income tax to an additional group of taxpayers. This step is the result of legislative changes aimed at reducing the administrative burden on taxpayers, whereby the Financial Administration automatically obtains information from other registers and carries out the registration on behalf of the taxpayer.

The original group of taxpayers that have been automatically registered ex officio by the Financial Administration since 6 October 2025.

▢ New list of taxpayers subject to ex officio registration

As part of ex officio registration, the Financial Administration will newly obtain information, in addition to the Register of Legal Entities, Entrepreneurs and Public Authorities, from the following additional registers:

• Register of Foundations
• Register of Non-Profit Organisations Providing Generally Beneficial Services
• Register of Trade Unions and Employers’ Organisations
• Special legislation establishing a public authority or a public-law organisation
• Register of Legal Entities Deriving Their Legal Personality from the Legal Personality of Churches and Religious Societies
• Register of Schools within the Regional Education System
• Register of Political Parties and Political Movements
• Register of Non-Investment Funds
• Register of Organisations with an International Element
• Register of Interest Associations of Legal Entities
• Register of Higher Education Institutions
• Register of Associations of Participants in Land Consolidation
• Register of Temporary Employment Agencies
• Register of Supported Employment Agencies
• Register of Churches and Religious Societies
• Register of Tourism Organisations
• Register of Public Research Institutions

With effect from 7 September 2026, the administrative obligation to submit a registration form will no longer apply to taxpayers registered in these registers.

▢ Exceptions

Automatic ex officio registration does not apply to taxpayers whose information is not recorded in the Register of Legal Entities, Entrepreneurs and Public Authorities. These taxpayers are still required to submit the registration form on their own initiative.

Since last year, this obligation has fully applied to taxpayers registered in the Commercial Register, Trade Register, Register of Owners of Apartments and Non-Residential Premises, as well as registers of experts, interpreters, financial advisers, attorneys, civic associations, municipalities, etc..

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 findings reached EUR 57.41 million, of which the findings specifically related to transfer pricing amounted to EUR 52.08 million.

These figures are an important signal for businesses carrying out significant transactions with related parties. The Financial Administration also expressly states that the high success rate of the audits is related to the effective use of analytical tools in the selection of entities, its own analytical assessments, and an in-depth assessment of their risk profile.

▢ Why is transfer pricing in the spotlight?

Transfer pricing may have a significant impact on the allocation of profits within a group and, consequently, on the tax base reported in Slovakia. At the same time, it is an area in which the Financial Administration has access to an increasingly broad range of structured data and analytical capabilities for identifying potential discrepancies.

Based on our experience, it is therefore no longer sufficient to have only formally prepared transfer pricing documentation. What is particularly important is the consistency of the data reported in the tax return, accounting records and transfer pricing documentation, as well as their consistency with the actual economic substance and the set-up of intra-group transactions.

▢ Which areas may increase the risk of a TP audit?

1) Profitability and financial performance

Particular attention in risk assessment may be attracted by persistently low profitability or recurring tax losses of a Slovak company, especially if they do not correspond to its functions, assets and risks or to the development of the group’s business. A significant deviation in profitability from comparable companies or a sudden change in the margin without an apparent economic reason may also be a risk indicator.

2) Significance and nature of controlled transactions

The more significant the volume of transactions between related parties and their impact on the Slovak tax base, the greater their relevance may be in the assessment of tax risk. In practice, particular attention should be paid, for example, to intra-group services, financing and interest, royalties, distribution and manufacturing models, as well as restructurings and transfers of functions, risks or intangible assets.

The OSEE administers selected economic entities that are among the largest taxpayers in Slovakia, such as banks, insurance companies and companies with annual turnover exceeding EUR 40 million. According to the Financial Administration, these companies often operate in an international environment, have complex structures and carry out complex transactions.

3) Data consistency and analytical selection of entities

We consider the shift towards data-driven selection of entities to be particularly important. The Financial Administration has directly confirmed the use of analytical tools, its own analytical assessments and an in-depth assessment of risk. In practice, this means that discrepancies between individual data sources may be identified even before the tax audit itself begins.

Therefore, as part of an internal TP risk assessment, we recommend reviewing in particular:

• whether the data on controlled transactions in the tax return correspond to the accounting records and transfer pricing documentation;
• whether the profitability achieved is consistent with the functional and risk profile of the Slovak company and the TP method applied;
• whether significant year-on-year changes in prices, margins or the volume of intra-group transactions can be economically explained;
• whether intra-group services, financing, licences and other significant payments are sufficiently documented and defensible; and
• for multinational groups, whether the locally reported data create any apparent discrepancies with information available to the tax authority through the international exchange of information, including CbCR, where relevant for the group.

▢ What does this mean for taxpayers?

The result of 15 findings out of 16 completed audits cannot automatically be applied to all taxpayers – these are audits of entities that had already been selected based on the OSEE risk assessment. However, this fact itself shows that analytical selection can be highly effective. The Financial Administration has also announced that it will continue its audit activities focused on transfer pricing in the second half of 2026.

We therefore recommend not waiting until a tax audit is announced. An appropriate step is a preventive TP health check – a review of the pricing arrangements, profitability achieved, documentation and, in particular, the consistency of data that the Financial Administration has or may have at its disposal. The objective is to identify and explain any potential risk indicators before they become the subject of an audit.

▢ How can we help you?

We would be pleased to assist you with a preventive assessment of TP risks, the setting or review of transfer prices, benchmarking, the preparation of transfer pricing documentation, as well as support during a tax audit.

At Moore Slovakia, transfer pricing is handled by a team of experts:

Martin Kiňo – Partner  I  martin.kino@moore-slovakia.sk

Elena Olejníková – Head of Tax  I  elena.olejnikova@moore-slovakia.sk

Michal Ištok – Transfer Pricing Expert  I  michal.istok@moore-slovakia.sk

Source: Financial Administration of the Slovak Republic, press release “OSEE Confirms High Effectiveness of Transfer Pricing Audits”, 22 July 2026.

The Slovak Republic has introduced a new reporting obligation for large corporations and multinational structures in the area of international tax transparency – the so-called income tax information report (Public Country-by-Country Reporting), which arises from the Accounting Act.

The main purpose of this reporting requirement is to provide the public with an overview of the economic activities of a group operating in different countries, the tax burden borne by the group, and to strengthen confidence in the transparency of the tax systems of individual countries.

▢ Who is subject to the new reporting obligation?

The statutory obligation to prepare an income tax information report primarily applies to companies at the top of an economic group – i.e. parent companies preparing consolidated financial statements.

The following table provides an overview of the rules applicable to different group entities:

Entity subject to reporting	Condition
Ultimate parent entity	Requirement to prepare consolidated financial statements if total consolidated revenue exceeded EUR 750 million (in at least two consecutive periods)
Standalone accounting entities	If total revenue or net turnover exceeded EUR 750 million (in at least two consecutive periods), even if the entity is not part of a group
Subsidiaries	If total revenue or net turnover exceeded EUR 750 million (in at least two consecutive periods) and the ultimate parent entity is located outside the EU (the report of the foreign parent entity is published)
Branches / organisational units	If they meet the standard size criteria set out below (and operate in Slovakia at the same time)

For the standard assessment of the size of an accounting entity, a company falls into the category of a large entity if it meets at least two of the following three criteria in each of the two consecutive preceding periods:

• total assets exceeding EUR 5 million,
• net turnover exceeding EUR 10 million; or
• an average number of employees exceeding 50.

▢ Exemptions from the obligation to submit the transparency report

The obligation to publish an income tax information report does not apply to companies that do not reach the EUR 750 million revenue threshold or do not meet the prescribed size criteria.

The Act also defines situations where the reporting obligation is considered to have been fulfilled automatically. This may be the case, for example, where the parent company publishes the report on its website in accordance with EU regulations and the report remains freely accessible to the public for a period of five years.

▢ Reporting deadlines

For businesses whose accounting period corresponds to the calendar year, the reporting obligation applies for the first time to the 2025 accounting period. The prepared report must be officially filed with the Register of Financial Statements and, at the same time, with the Collection of Documents of the Commercial Register.

• the report must be filed no later than one year after the end of the relevant accounting period.

Accordingly, the deadline for the 2025 reporting period is 31 December 2026.

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 corporate sustainability reporting, the scope of information to be reported and the extent of the reporting requirements applicable to the affected undertakings have been revised.

▢ What changes does the amendment introduce?

The EU Directive, which also amends the Accounting Act, changes the scope of undertakings subject to the obligation to include sustainability information in their annual report. In addition to the National Bank of Slovakia and health insurance companies, the obligation will apply to every undertaking that meets the following criteria:

Definitoin criteria	Current criteria	Proposed criteria
Total assets	EUR 25 million	Removed
Net turnover	EUR 50 million	EUR 450 million
Average number of employees during the accounting period	250	1 000

 

These conditions will also apply to an undertaking that meets these thresholds as at the balance sheet date. At the same time, undertakings issuing securities admitted to trading on a regulated market will no longer be subject to a separate assessment.

As another measure aimed at reducing the number of undertakings required to report consolidated sustainability information, the concept of a “financial holding accounting entity” is being introduced. This refers to an undertaking that is a business company whose sole activity is the acquisition of interests in other undertakings and their management and appreciation, without directly managing those undertakings.

An undertaking falling within this definition will not be entitled to report sustainability information under the procedure applicable to micro accounting entities.

▢ Impact on the statutory audit of annual reports containing sustainability information

The amendment to the Accounting Act will also affect the statutory audit of annual reports containing corporate sustainability information. Following the amendment to the Statutory Audit Act, such an audit may only be performed by a so-called key audit partner, who is a statutory auditor registered in the register of statutory auditors.

Also, requirements will be introduced for the registration of third-country auditors and third-country audit firms for the purpose of providing assurance services in the area of sustainability reporting.

Such third-country persons will be registered by the Office for the purposes of providing assurance on sustainability reporting where they have issued an assurance report relating to the sustainability reporting of a third-country company for an accounting period beginning between 1 January 2025 and 31 December 2030.

Registration will only be carried out upon payment of the registration fee.

The proposed effective date of the amendments to the Accounting Act and the Statutory Audit Act is 1 January 2027.

In Moore Slovakia, our tax experts everyday monitor Slovak tax legislation for you, our business partners and clients. In this respect, we would like to draw your attention to an important change in the area of withholding tax that affects payments for the use of software acquired from foreign suppliers, we informed you in our recent article.

This change results from the fact that the Slovak Republic has withdrawn its reservation to the interpretation of the OECD Model Tax Convention. Until the end of 2025, this reservation allowed a distinction between standardised software and customised software for the taxation of royalties.

▢ The impact of new guidance to Slovak business

From 1 January 2026, payments for the right to use any software, including customised or non-standard software, are treated as “royalties” for withholding tax purposes in Slovakia.

This applies even where there is no full transfer of ownership rights and the customer receives only the right to use the software. Such payments may therefore be taxed under the applicable double tax treaty.

This means:

• payments for the right to use software may be treated as royalties under the relevant double tax treaty.
• this applies regardless of whether the software is standardised software that is commercially available or customised software.

▢ What is impact for Slovak companies?

If a Slovak company pays a foreign supplier for the right to use software, these payments may be treated as royalties and may be subject to withholding tax under the applicable double tax treaty.

If you receive and pay invoices for standardised software, it is necessary to review the relevant double tax treaty.

If Article 12 (Royalties) of the treaty includes software within the definition of royalties, payments for the right to use software will be subject to withholding tax from 2026.

For example, the double tax treaty between Slovakia and the Czech Republic provides the following definition:

The term “royalties”, as used in this Article, means payments of any kind received as consideration for the use of, or the right to use:

(a) any copyright, patent, trademark, design or model, plan, secret formula or process, computer software, or any industrial, commercial or scientific equipment, or for information concerning industrial, commercial or scientific experience.

Under the Slovakia–Czech Republic double tax treaty, payments for the use of standardised software are subject to withholding tax because software is expressly included in the definition of royalties in Article 12.

If you are involved in cross-border software licensing transactions, we recommend identifying these transactions and reviewing the relevant double tax treaty, as the withholding tax treatment must be assessed on a case-by-case basis.

We will be happy to assist you with this analysis. If you have concerns about the current taxation of royalty payments or are unsure how to correctly set up the applicable tax treatment, please do not hesitate to contact us.

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.

Basic information about the exchange of information under the GIR MCAA, including the list of the first signatories, is available in our previous article.

▢ Current list of jurisdictions participating in the GIR MCAA

The latest list of signatories to the GIR MCAA now includes 31 jurisdictions that cooperate internationally on the reporting and exchange of information for global minimum tax purposes.

As of 15 April 2026, the latest jurisdictions to join the agreement are:

• Canada
• Greece
• Gibraltar
• Singapore
• Australia
• Isle of Man

Within the European Union, several Member States have not yet implemented the DAC9 Directive into their domestic legislation and have not signed the GIR MCAA. These countries include Bulgaria, Cyprus, the Czech Republic, and Cyprus.

The current list of jurisdictions participating in the GIR MCAA is available on the following website. This list is particularly relevant for taxpayers that are subject to the global minimum tax in Slovakia.

▢ Why is it important to know the GIR MCAA Signatories?

The GIR MCAA enables the automatic exchange of information between the tax authorities of jurisdictions in which a multinational enterprise group operates through one or more constituent entities.

The information exchanged consists of data reported in the GloBE Information Return (GIR). This information is important for the reporting obligations of the entire multinational group. One of the key aspects of this cooperation is the exchange of information between the jurisdictions where the constituent entities and the filing entity are located regarding the submission of the GloBE Information Return.

 

The EU has decided to address the increasing volume of low-value goods imported in small consignments with a value not exceeding EUR 150, which European consumers order through online platforms. The new rules abolish the existing customs duty exemption for these small consignments.

Below is an overview of the planned customs changes for the delivery of so-called small consignments. These changes have been in effect since across the European Union from 1 July 2026.

▢ New ruling

When ordering low-value goods from a third country, recipients should pay attention to the applicable EU rules for good consignments with a total intrinsic value not exceeding EUR 150.

The table below compares the old and new rules:

	Rules applicable until 30 June 2026	Rules applicable from 1 July 2026
Customs duty	Customs duty exemption applies to good consignments with a value of up to EUR 150	The current customs duty exemption for good consignments with a value of up to EUR 150 is abolished
Flat-rate customs duty	Not applicable	A temporary flat-rate customs duty is introduced
VAT	Every good consignment is subject to VAT, regardless its value	Every good consignment is subject to VAT, regardless of its value

▢ Why is a „Temporary“ – Flat-Rate customs duty introduced?

The EU plans to upgrade its centralised technical system for the administration and collection of customs duties on low-value consignments sold through distance sales. During the transitional period from 1 July 2026 to 1 July 2028, the IT infrastructure for the new system (the EU Customs Data Hub) will not yet be fully operational. Therefore, a temporary flat-rate customs duty of EUR 3 applies.

The temporary flat-rate customs duty is charged if:

• the foreign seller is registered for VAT under the Import One-Stop Shop (IOSS) scheme;
• the goods are imported in a postal consignment under the EU special scheme.

The temporary flat-rate customs duty is not charged once per consignment. Instead, it is calculated separately for each product based on its customs tariff classification. This means that if a parcel contains products belonging to different tariff categories, the flat-rate customs duty will be charged once for each category. If the parcel contains several products within the same tariff category, the flat-rate customs duty will be charged only once for that category.

The practical consequences do not apply to orders fulfilled from a warehouse located within the EU, where goods were already imported for purposes of customs duty-free regime. In such cases, the customer should not be charged the additional flat-rate customs duty.

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 the key changes for businesses in this area.

Key changes in the methodological guidance

The Slovak Republic has withdrawn its reservations regarding the interpretation of the OECD Model Tax Convention for the Avoidance of Double Taxation. Until now, this interpretation distinguished between standardised software and customised software for the taxation of royalties.

Payments for the right to use software, regardless of whether the software is customised or standardised, are considered royalties for withholding tax purposes from 2026.

From 2026, the guidance applies to all forms of payment, regardless of the payment method:

• sale
• licensing
• provision of services
• transfer of rights

Classification of software payments

The new guidance distinguishes between different software payments and categorises them as follows:

Software payments subject to withholding tax
Granting the right to commercial use of copyrighted software	Includes payments for the right to commercially use, reproduce, process, translate, or modify software
Provision of software development know-how	Includes remuneration for the provision of knowledge, plans, and source codes for software development in the form of know-how
Software payments not subject to withholding tax
Provision of software services	Includes payments for remote access to software or source code, or access for modification and copying (downloading) of software
Provision of software as a product	Includes payments for created copies of software with limited copyright rights, where the user is only entitled to install the software, create backup copies, or make specific modifications
Transfer of copyright	Represents the sale of copyright to software, clearly defined in the sale agreement, where the author agrees to the transfer of the result of their intellectual and creative activity. Such income is taxable in the country of residence of the recipient

If any of the above forms of services, products, or rights are contractually defined as a “royalty”, such payments are subject to withholding tax.

Impact of the guidance on businesses

If a Slovak company pays a foreign provider for the right to use software, such payments may be treated as royalties and may be subject to withholding tax or other taxation under the relevant international tax treaty.

We therefore recommend that businesses focus on the following areas:

• review the relevant software agreement and determine the type of payment involved
• assess the tax implications of the new guidance for both new agreements and existing agreements if income continues to arise after 31 December 2025
• properly structure contractual relationships with foreign software providers