Double-Tax Treaty is a key instrument in the international tax system to avoid taxation of the same income in two different countries. In this article, we look at the most significant changes to these treaties that entered into force on 1 January 2025, as well as new agreements concluded during 2025 in Slovakia.
These changes are important for taxpayers doing business or investing internationally.
◻ New Double-Tax Treaties
During 2025, only one new double taxation treaty was signed between the Slovak Republic and the Kyrgyz Republic.
The Treaty will enter into force on 1 March 2025 in accordance with Article 28 of the Treaty.
Serial number in the list of valid and effective treaties | Full Treaty Name | Number in the Act Book |
| 33 | Treaty between the Slovak Republic and the Kyrgyz Republic for the avoidance of double taxation in the field of income taxes and the prevention of tax evasion and avoidance | 12/2025 |
Kyrgyzstan joins the following countries that became contracting states under the treaty last year but the actual text of the treaties only entered into force on 1 January 2025:
- Albania
- Azerbaijan
- New Zealand
- Saudi Arabia
◻ Treaties that have been amended
During the last period, a number of amendments concerning the implementation of the Multilateral Convention (Multilateral Instrument) have been adopted and incorporated. These amendments cover several areas, while only two Double-Tax Treaty is concerned.
The list of adopted amendments and the country concerned is summarised in the following table
Country | Topic that has changed |
| Germany | – Permanent Establishment definition – Sale of shares in companies that own real estate (so-called share deals) – Method of avoiding double taxation – Settlement of cases by agreement (so-called MAP) |
| Moldova | – Addition of the concept of pension fund and its meaning – Clarification of the definition of resident and permanent establishment – Dividends with ownership of at least 25% of the company’s assets – Alienation of assets with a 50% interest in immovable property – Addition of eligible benefits |
The amendments to the double taxation treaty entered into force on 16 October 2024.
A complete list of valid and effective double taxation treaties can be found on the website of the Ministry of Finance of the Slovak Republic under Income Taxes – Double Taxation Treaties (available in Slovak language only).
