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.
