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This change results from the fact that the Slovak Republic has withdrawn its reservation to the interpretation of the OECD Model Tax Convention.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

The Slovak Parliament approved a government bill amending and supplementing the Act on Protection Against Money Laundering and Terrorist Financing (AML). The amendment addresses deficiencies in Slovak legislation identified by the Committee of Experts of the Council of Europe on the Evaluation of Anti-Money Laundering Measures.

The previous legislation showed significant deficiencies in the identification and verification of beneficial owners, trust arrangements, identification of persons performing management functions, and powers related to suspicious transactions.

Overview of the main changes

The most important changes introduced by the government bill affect several laws, mainly the Act on Protection Against Money Laundering and Terrorist Financing. The main amendments include the following:

• 1) Amendment to the definition of the beneficial owner in the case of an arrangement of assets – when identifying future beneficiaries of funds, it will no longer be required that such persons receive a “significant” benefit from the establishment or operation of the arrangement of assets. Also, the definition is supplemented by a new rule under which a natural person is considered a beneficial owner if that person exercises actual control over the assets of the arrangement through direct or indirect ownership or by other means.
• 2) Inclusion of the concept of a trust – an arrangement of assets in the form of a foreign trust is also considered an arrangement in which a natural person benefits as a beneficial owner.
• 3) Identification of members of the governing body of a legal entity – the identification process for legal entities as beneficial owners is amended. In addition to the name and surname of the managing director, the names and surnames of persons who are members of the governing body of the legal entity or arrangement of assets must also be identified.
• 4) Verification from multiple sources – the so-called basic due diligence procedure is amended. Information on beneficial owners must now be verified not only through the Commercial Register, but also through the Register of Legal Entities and Public Authorities, as well as foundation agreements and related documents.

If an unusual transaction is identified, a report on an unusual business operation must be submitted immediately.

• 5) New GoAML information system – the legislation formally incorporates the new information system of the Financial Intelligence Unit of the Police Presidium for the receipt and analysis of unusual business operations. The system has already been operational since 1 January 2025. Reporting entities must register in this information system within 30 days from the identification of an unusual business transaction.
• 6) Administration of foreign trusts – a trustee of a foreign trust established in Slovakia will be required to maintain and update records of managed assets for at least five years.

Register of foreign trusts

The government bill introduces a new register of foreign trusts. The register will be administered by the Ministry of Interior of the Slovak Republic as a public administration information system. This change follows recommendations of the European Commission requiring Slovak legislation to address foreign trust arrangements.

This mainly concerns situations where:

• a trust established under foreign law has links to Slovakia
• the trustee has residence in Slovakia
• business relationships are carried out in Slovakia
• real estate under trust administration is located in Slovakia

A trustee of a foreign trust established in Slovakia will therefore be required to register beneficial ownership information in the following structure:

• name or designation of the foreign trust
• registered office or address where the trust is administered, if no registered office exists
• identifier assigned to the foreign trust in the state where it was established
• identification details of the settlor, trustee, person supervising the administration of the trust, beneficiaries of the trust assets, and persons exercising actual control over the trust
• details of the beneficial owner

Registration may be carried out at any district office located in a regional capital. The foreign trust will receive a unique identifier under which it will be recorded in the register of foreign trusts.

Registration of a foreign trust in the register does not affect cadastral proceedings or the validity of agreements under which a foreign trust acquires real estate. The cadastral department of the district office will not examine registration in the register of foreign trusts.

Amendments related to other legislation

As part of addressing deficiencies in Slovak legislation, the government also incorporated amendments into other laws. Below is a summary of the most important impacts on legal entities and individuals in business activities.:

Type of legislation	Description of amendment or impact
Trade Licensing Act	The Act introduces a condition of integrity of the beneficial owner for legal entities authorised to provide asset management services, for example activities related to the start of business operations
Administrative Fees Act	The schedule of administrative fees is supplemented by official fees for: registration of a foreign trust (EUR 100) and changes to registered data (EUR 25)
Act on the Register of Legal Entities, Entrepreneurs and Public Authorities	Data from the register of foreign trusts will be provided to the Register of Legal Entities, Entrepreneurs and Public Authorities, which serves as the central register of beneficial owners.   At the same time, unrestricted access to the register of beneficial owners will be limited. For the protection of personal data, access will only be granted upon demonstration of a legitimate interest related to the prevention of money laundering, terrorist financing, related predicate offences, and measures against them.
Act on the Implementation of International Sanctions	The amendments introduce a more effective administrative procedure for the implementation of international sanctions in accordance with FATF requirements. The Act will also allow sanctions to be imposed for misdemeanours

All of the above amendments will enter into force on 1 June 2026.

Practical implications

In connection with the amendments concerning beneficial owners and foreign trusts, we would like to highlight the following practical implications of the government bill:

• stricter identification of beneficial owners and increased administrative burden for verification of information
• increased requirements for foreign clients and identification of their beneficial owners
• mandatory registration of foreign trusts
• stricter verification of transactions, ownership structures, and business relationships involving foreign trusts
• increased administrative burden and costs related to new reporting obligations and updates of internal verification processes

About the Client
SF1 Clips helps international brands such as Victoria’s Secret, Pandora, and Nespresso enter the markets of Central and Eastern Europe. Their business model is flexible and adapts to the specific needs of each brand, while at the same time requiring a unified approach to process management across countries.

When expanding into new markets, SF1 Clips needs to ensure a consistent flow of data in areas such as accounting, invoicing, inventory management, point-of-sale systems, and reporting. The key objective is to have a centralized yet scalable system that supports further growth.

Challenge
When entering the Slovak market, SF1 Clips faced the question of how to set up local accounting and processes in compliance with Slovak legislation while still fitting into their existing international ERP environment.

The challenge was not only technological. It also included aligning different accounting standards, ensuring proper tax setup, handling registration obligations, and creating processes that would be sustainable in the long term and ready for scaling. Equally important was the ability to integrate the ERP system with local solutions and ensure its practical use in daily operations.

Solution
A key element of the solution was the digitalization of processes through the Odoo ERP system, which enabled the integration of accounting, invoicing, inventory management, and point-of-sale operations into a single system.

In cooperation with 26HOUSE, accounting modules were implemented, the POS system including eKasa was configured, invoicing and exchange rate calculations were automated, and integration with the Slovak accounting system POHODA was established. The integration of accounting was essential to ensure compliance with local legislation.

The implementation and integration of accounting required more than 30 hours of IT support, highlighting the technical complexity and the importance of properly setting up all processes from the very beginning. IT support and the implementation of accounting modules within the Odoo system were provided by the Slovak partner Moore BDR.

Partner
The project was built on the cooperation of two Slovak partners who complemented each other. 26HOUSE was responsible for the implementation of the Odoo ERP system and its technical setup, including localization and integrations.

In addition to IT support, Moore BDR focused on accounting, tax, and legislative areas. In the initial phase of the project, more than 40 hours were dedicated to tax advisory and transfer pricing to ensure that the overall structure was set up correctly from the start. The support also included legal and registration services, such as company and employee registration and communication with relevant authorities.

After the launch of SF1 Clips’ operations, Moore BDR has been providing ongoing support, including payroll accounting for more than 50 employees, processing approximately 7,000 accounting entries per month, VAT agenda, reporting, and communication with authorities.

Result
The result of this collaboration is a functional and scalable model that enables SF1 Clips to operate efficiently in the Slovak market while maintaining unified processes within its international environment.

The integration of accounting, digitalization, and the Odoo ERP system created a stable foundation that connects technological solutions with local requirements. This approach not only addresses current needs but also prepares the company for further growth and expansion into additional markets.

This case demonstrates that the key factor for success is not only the implementation of a system or the provision of accounting services, but above all their integration and effective cooperation between partners.

If you are planning to enter the Slovak market or optimize your business processes, we will be happy to become your long-term partner.

In February, the Slovak Parliament approved a new Commercial Register Act. This Act replaces Act No. 530/2003, which had been in force since 2003. The new Act aims to improve the administrative process for registrations and changes in the Commercial Register and to accelerate procedures for entrepreneurs.

We would like to provide you with a brief overview of the new measures for entrepreneurs and business.

• Main purpose of the new Act

The main purpose of the new Commercial Register Act is to incorporate all Commercial Register rules into one legal regulation, including the creation of a basis for a new Commercial Register information system.

In order to accelerate procedures and reduce the administrative burden, the Act focuses on:

• introducing the legal binding effect of online published data without the need to prove Commercial Register data between entrepreneurs
• enabling the interconnection of data with other information registers
• reserving a company business name for 60 days for the purpose of building business awareness
• obtaining a trade licence for a free trade activity solely by registration in the Commercial Register
• enabling registrations through notarial deeds (so-called accelerated registration process)

New form of authorisation and representation of entrepreneurs

Selected legal documents submitted for registration in the Commercial Register will no longer require a notarised signature. This requirement will be replaced by:

• authorisation by an attorney-at-law
• execution in the form of a notarial deed

Also, an entrepreneur may be represented before the Commercial Register authority not only by its statutory representative or by the entrepreneur itself, but also by an attorney-at-law, a notary, or an employee of the entrepreneur authorised by a notarised power of attorney.

The new Act also introduces preventive measures in the processing of data, in particular:

• preventive review of submitted corporate documents before registration in the Commercial Register for verification purposes
• possibility to prepare amendments to foundation documents and articles of association in the form of a notarial deed in order to ensure legal certainty

Scope of published data

The new Act introduces a rule under which only data expressly required by law will be registered in the Commercial Register. The purpose is to align registered data with verified documents.

The catalogue of data maintained in the Commercial Register will have a uniform format for registered data, taking into account the registration of persons under special legislation that may require a different structure of published data.

• Abolition of the prohibition on company chaining

The abolition of the prohibition on company chaining means that entrepreneurs will no longer be restricted when establishing companies in the position of shareholders or partners. This change will allow a single-member limited liability company to establish another single-member limited liability company as its sole shareholder

• Penalties

The sanction mechanism will also change. Compared to the previous practice, where sanctions were imposed only rarely, the new approach introduces stricter rules for penalties. As with other administrative fees, penalties will increase. For example, the original penalty of EUR 3,310 for failure to submit an application for registration of changes within the statutory deadline will increase to EUR 4,000.

• Effective date of the Act

The new Act has been signed by the President of the Slovak Republic and will enter into force on 17 August 2026.

The Commercial Register will continue to be administered by the registration court, which is responsible for its active management. The rule remains unchanged that district courts are the competent courts for maintaining the Commercial Register.

The European Union (the ECOFIN Council) updated its list of non-cooperative jurisdictions for tax purposes in February 2026. These jurisdictions do not cooperate with EU Member States in tax matters. The list is updated twice a year, at the beginning of spring and in the middle of autumn.

We would like to provide you with our regular update to the latest tax development.

The current list of non-cooperative jurisdictions for tax purposes includes 10 countries and territories:

• American Samoa
• Anguilla
• Guam
• Palau
• Panama
• Russia
• Turks a Caicos Islands
• S. Virgin Island
• Vanuatu
• Vietnam

The Turks and Caicos Islands were added to the so-called Black List due to the support of offshore structures. Vietnam was added due to insufficient exchange of information in the area of DAC4 / CbCR.

At the same time, the following countries were removed from the list following a reassessment and amendments to their tax legislation:

Fiji	Signed an agreement on administrative cooperation and the elimination of harmful tax regimes
Samoa	Abolished its preferential offshore regime
Trinidad a Tobago	Improved the automatic exchange of information in accordance with OECD standards

 

The so-called Grey List continues to include countries such as Belize, the British Virgin Islands, Brunei Darussalam, Eswatini, Greenland, Jordan, Montenegro, Morocco, and Turkey. These jurisdictions remain subject to a detailed review of their tax regimes.

The next revision of the list of non-cooperative jurisdictions is scheduled for autumn (October) 2026.