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The Slovak Republic has withdrawn its reservations regarding the interpretation of the OECD Model Tax Convention for the Avoidance of Double Taxation.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.

The Financial Administration of the Slovak Republic has published a template and an official electronic form for the Notification on the Use of a Passenger Motor Vehicle for Business Purposes (published template of notification form in Slovakia – OZNMVv26). The new form must be used by all entrepreneurs who, as of the new year, declare a 100% entitlement to deduct VAT on motor vehicles used for business purposes.

The new requirements arising from the amendment to the VAT Act introduce additional administrative obligations, which are contrary to the information previously presented by the Ministry of Finance of the Slovak Republic.

• What Does the New Form Contain?

The new form is filed as part of a reporting obligation that must be fulfilled by all taxpayers (VAT payers) if they apply a 100% VAT deduction on the use of motor vehicles in category M1 and motorcycles in categories L1e and L3e for business purposes.

The purpose of the form is to notify the tax authorities of data concerning vehicles for which a 100% VAT deduction is applied, as well as any changes relating to the registration or scope of the taxpayer’s vehicle fleet. This means that the form is submitted only exceptionally when reporting new data or changes thereto

For this reason, in the event of a change to previously notified data, the date on which the original (i.e. previous) notification was submitted must also be indicated.

The form itself is divided into three parts, which are briefly described below:

Part I – Data on the Motor Vehicle

This part indicates the manner in which the motor vehicle is used for business purposes. Accordingly, this section begins with information about the vehicle, followed by an indication of its use within leasing activities, taxi services, driving school operations, etc.

Part II – Information on the Change in Use of the Motor Vehicle

The second part contains information about a change in the use of the vehicle from exclusively business purposes to purposes subject to exemption from the application of the special VAT scheme (e.g. use of the vehicle for short-term rental, taxi services, driving school operations, or vehicle demonstration activities).

Part III – Notification of the Commencement of Use of a Motor Vehicle

In this part, the taxpayer informs the tax authority about a motor vehicle that will be used (changed) from the following tax period exclusively for:

• short-term rental,
• transport within taxi services,
• operation of a driving school,
• vehicle demonstration or testing,
• business purposes (100% use)

If the Part III is to be inserted – in the field indicating the calendar year, the “following year” must always be stated.

In each part, information and data relating to each motor vehicle are provided separately. This means that each passenger car must be entered individually in the respective sections using the “Add” record function. In each part, the taxpayer provides the same information concerning:

• • the vehicle identification number (VIN),
  • the vehicle registration number (licence plate number),
  • the name and type of the vehicle,
  • the vehicle category (selected only from M1, L1e, and L3e).

• Where Can the New Notification Form Be Found?

The new electronic form is available in the Financial Administration’s catalogue of forms under the section Tax Administration – VAT forms. Currently, there is no English version of such notification available.

However, this notification does not contain any instructions for completion. Therefore, in case of questions, taxpayers must contact the Financial Administration’s call centre or their tax adviser.

The Ministry of Finance of the Slovak Republic has published the announced measure determining the basic subsistence allowance rates for foreign business trips. At the same time, for selected countries, the subsistence allowance has been set in the local currency instead of the original currency, the euro.

Below, we provide an updated overview of subsistence allowance rates for foreign business trips effective from 2026.

Country	Currency Code	Currency	Specific basic subsistence allowance rates
Belgium	EUR	euro	63
Belarus	EUR	euro	55
Bulgaria	EUR	euro	43
Cyprus	EUR	euro	57
Czechia	CZK	Czech crown	1 200
Denmark	DKK	Danish crown	456
Estonia	EUR	euro	50
Finland	EUR	euro	60
France	EUR	euro	63
Greece	EUR	euro	59
Netherlands	EUR	euro	63
Croatia	EUR	euro	56
Ireland	EUR	euro	64
Lithuania	EUR	euro	56
Latvia	EUR	euro	56
Luxemburg	EUR	euro	60
Hungary	EUR	euro	55
Malta	EUR	euro	54
Germany	EUR	euro	63
Poland	EUR	euro	52
Portugal	EUR	euro	60
Austria	EUR	euro	63
Romania	EUR	euro	60
Russia	EUR	euro	55
Slovenia	EUR	euro	53
Serbia	EUR	euro	60
Spain	EUR	euro	60
Sweden	SEK	Swedish crown	637
Italy	EUR	euro	63
Türkiye	EUR	euro	62
Ukraine	EUR	euro	52

The new measure entered into force on 30 January 2026.

Unlike previous measures, this measure does not specify a fixed period of validity, as the Ministry will update it in line with price developments in the respective countries.

With the introduction of the new Consolidation Package we informed you here recently, new rules will come into force for all businesses regarding the use of company car and the deduction of VAT related to such use. These changes will have a significant impact not only on VAT but also on income tax and the provision of company cars as employee benefits – below is a comprehensive overview of the new rules applicable from 1 January 2026

The current VAT deduction system for company cars, based on a proportional rate of 80/20, will be replaced by a new flat-rate deduction. This change aligns Slovak regulations with European legislation.

Comparison of VAT Deduction

Please find below overview of current and new-year rules for company car use:

Ude of company car	Current rule (until December 2025)	New rule (from January 2026)
Business purposes only (exclusive business use)	100%	100% (if detailed records are kept)
		50% (if no records are kept)
Mixed purposes (business and private use)	proportional deduction based on actual business use (for example 80% deductible)	50% (flat rate, regardless of record-keeping)

The new rules apply only to selected company cars in categories M1, L1e, and L3e (for example, passenger cars, mopeds, and motorcycles). If these cars are used for both business and private purposes, the flat-rate VAT deduction of 50% will apply to:

• purchase, lease, rental, or import of cars in these categories within a defined period (1 January 2026 – 30 June 2028) *
• purchase of goods and services related to the operation of these cars of the above categories, such as purchase of fuel, spare parts, accessories, servicing, or maintenance.

* The new flat-rate VAT deduction for mixed use applies only for a limited period under European legislation, during which a VAT deduction exemption is granted.

Exceptions to the New VAT Deduction Rules

The new VAT deduction rules do not apply to certain cars, in particular those that are:

• used exclusively for business purposes = the entrepreneur must keep detailed records for each car individually
• used for specific purposes = which are excluded from the special VAT deduction regime. These include cars:
• intended solely for sale, rental, or leasing
• used for taxi services or driving schools
• used as demonstration, test, or replacement cars

Administrative Obligations

• Record-Keeping

Where a company car is used solely for business purposes, a detailed electronic logbook must be maintained for each car, containing the following information:

• car identification details
• odometer readings at the start and end of the reporting period and at the end of each tax period
• detailed records of each journey
• records of goods and services purchased for the operation of the car

A key advantage of the new rules is that, for mixed-use car, detailed record-keeping will no longer be required, as the 50% flat-rate deduction applies automatically. However, if the car is provided as an employee benefit, maintaining detailed records remains advisable.

• Notification to the Tax Office

The new rules introduce an obligation for VAT payers to notify the tax office if a company car is used solely for business purposes or if one of the exceptions above applies.
Notification is also required when changing from the flat-rate deduction (50%) to full deduction (100%).

This notification must be submitted for the tax period in which the VAT deduction is first claimed for the purchase or initial lease of the company cars.

Impact on Income Tax

The new VAT deduction rules will also affect tax-deductible expenses related to company vehicles from 1 January 2026. If a company vehicle is used for mixed purposes and the 50% VAT deduction is applied, the non-deducted VAT portion will be treated as a non-deductible expense.

Impact on Employee Benefits

Using company vehicles as an employee benefit remains a popular practice. However, this area will also be affected by the new VAT deduction rules. The following provides an overview of the most common form of this benefit.

• Use of Company Vehicles

Fuel costs related to the private use of company cars (provided that the private use is taxed as a non-cash benefit for the employee) may be included only in proportion to the business use of the car.

If the company car is used exclusively for business purposes, 100% of the expenses related to its use are tax-deductible, provided that the employee’s benefit is properly taxed as income.

• Provision of Company Parking Spaces

If the employer allows an employee to park in a company car park, this is considered an employee benefit and should be taxed accordingly. In such cases, parking costs are fully tax-deductible, regardless of whether the company vehicle is also used privately.

It is essential that the use of parking spaces by employees is properly recorded (tax evidence) and verifiable.

This type of benefit may be included under the provision exempting non-cash income up to EUR 500. A detailed internal company policy defining the rules and conditions for the use of parking spaces is strongly recommended.

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).

As part of the recently approved 3rd consolidation package, a general waiver of penalties – the so-called tax amnesty – was introduced. This instrument applies to all taxpayers who have failed to pay part of their tax liability. Below, we provide an overview of the practical interpretation of the tax amnesty, which is valid only for the first half of 2026.

• To Which Taxes Does the Penalty Waiver Apply?

The possibility of late payment of a tax liability or tax arrears applies to the following tax areas:

The tax amnesty APPLIES to the following taxes	The tax amnesty DOES NOT APPLY to the following taxes
VAT Corporate and Personal income tax Excise duties Motor vehicle tax Insurance tax	Tax prepayments Tax instalments Special levy on business in regulated sectors Solidarity contribution Local taxes and municipal waste change

We again emphasise that the waiver of penalties for late payment (tax amnesty) applies only to the settlement of these arrears in the period from 1 January 2026 to 30 June 2026. Tax arrears arising between 1 October and 31 December 2025 are not subject to the tax amnesty.

This legislation was adopted by Government Regulation of the Slovak Republic No. 243/2025 Coll. of 10 September 2025 on the extinction of tax arrears corresponding to an unpaid sanction related to a paid tax and on the waiver of the imposition of a penalty and the assessment of late-payment interest.

• How Will the Tax Amnesty Apply in Practice?

In the case of the tax amnesty, it is relevant when the tax arrears were paid or when the tax return determining the payable tax liability was filed. It is therefore necessary to distinguish between two different situations.

In essence, a voluntary settlement of tax arrears is introduced within a “substitute transitional period” referred to as the tax amnesty.

[1] Payment of Tax Arrears During the Tax Amnesty

Payment of tax arrears existing as of 30 September 2025, which are settled between 1 January 2026 and 30 June 2026, results in:

• a waiver of the imposition of a penalty pursuant to the Tax Code, or
• the extinction of tax arrears in the amount corresponding to the unpaid penalty or unpaid late-payment interest relating to that tax as of 30 June 2026.

[2] Settlement of Tax Arrears by Filing a Tax Return During the Tax Amnesty

The filing of a tax return for which the statutory filing deadline expired by 30 September 2025, provided that the calculated tax liability is paid between 1 January 2026 and 30 June 2026, results in:

• a waiver of the imposition of a penalty pursuant to the Tax Code, or
• a waiver of the assessment of late-payment interest relating to the tax arrears

This applies to the filing of a regular or additional tax return for which the filing deadline expired by 30 September 2025.

Particular Considerations Regarding the Government Regulation

The adopted Government Regulation of the Slovak Republic governing the tax amnesty does not provide a precise definition of how “payment” must be effective or the exact conditions under which the tax administrator will apply the tax amnesty to a taxpayer.

At the same time, the explanatory memorandum states that the condition does not apply to the settlement of arrears through the offsetting of overpayments against arrears or to the recovery of arrears through tax enforcement proceedings.

For the proper assessment of the impact of the tax amnesty on existing tax arrears, we recommend precisely identifying the period to which the tax arrears from unpaid tax or from assessed interest or penalties relate.