Registration of a VAT Group by the Tax Authority

As part of the implementation of measures to combat tax fraud and prevent VAT evasion, Slovakia has adopted an amendment to the VAT Act introducing new conditions for the registration of a VAT group by the tax authority. These conditions apply from 1 January 2026.

The new legislation focuses on entrepreneurs operating through multiple companies that are formally established as separate entities but are interconnected, with the primary aim of avoiding VAT registration obligations.

• Reason for Registration by the Tax Authority

If several related entities conduct business with the main objective of avoiding tax payment, the tax authority may initiate registration of a VAT group by its own decision. If the tax authority starts proceedings for group registration by official decision – individual members will not be registered separately under Section 4b of the VAT Act.

• When Will the Tax Authority Proceed with Official Registration?

If, during tax administration, inspections, or based on other findings, the tax authority determines that the conditions for VAT group registration of several entities have been met, it has the authority to:

• invite all presumed group members;
• request the designation of a group representative;
• appoint a group representative if the members fail to do so.

The tax authority requires the designation of a group representative within 8 days from the delivery of the request.

Subsequently, the tax authority invites the group representative to comment on the reasons for the intended registration within a period of at least 15 days from delivery of the request. After reviewing the response, the tax authority decides as follow:

The appointed group representative may file an appeal within 8 days from the delivery of the decision on group registration by official decision.

The common VAT identification number becomes valid on the day following the finality of the decision on group registration (on that date, the original VAT numbers assigned in Slovakia to the individual members cease to exist).

• Authority Responsible for Group Registration?

Under the applicable legislation, the Tax Office in Banská Bystrica is responsible for managing and processing VAT group registrations.

After official registration, the competent tax administrator becomes the tax office relevant to the seat of the group representative. This means that the Tax Office in Banská Bystrica performs the registration, but not the subsequent tax administration.

• Procedure When Additional Members Meet the Conditions

If existing or new members meet the conditions for inclusion in the VAT group – the group representative must immediately request an amendment to the group registration. The same applies if a member ceases to meet the legal conditions for group membership.

Failure to fulfil this obligation may result in a fine of up to EUR 10,000 imposed by the tax authority competent according to the seat of the group representative. When determining the amount of the fine, the tax authority considers the seriousness, duration, and consequences of the unlawful situation.

• Consequences of Registration by the Tax Authority

Following the change from individual registration to VAT group registration by official decision, new conditions apply to the members, particularly regarding transactions between them. The main consequences include:

• All members use a single VAT identification number on invoices issued to third parties;
• Transactions between group members are not subject to VAT;
• Reduced administrative burden for intra-group transactions;
• Joint liability for the fulfilment of tax obligations;
• Members may be included in tax inspections concerning another group member.