{"id":9858,"date":"2026-05-25T14:35:03","date_gmt":"2026-05-25T12:35:03","guid":{"rendered":"https:\/\/www.moore-bdr.sk\/?p=9858"},"modified":"2026-08-03T11:33:23","modified_gmt":"2026-08-03T09:33:23","slug":"nove-usmernenie-k-zrazkovej-dani-z-platieb-za-softver","status":"publish","type":"post","link":"https:\/\/www.moore-bdr.sk\/en\/nove-usmernenie-k-zrazkovej-dani-z-platieb-za-softver\/","title":{"rendered":"Status update to Slovak guidance on withholding tax for software payments"},"content":{"rendered":"

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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<\/strong>, we informed you in our recent article<\/a>.<\/p>\n

This change results from the fact that the Slovak Republic has withdrawn its reservation to the interpretation of the OECD Model Tax Convention<\/strong>. Until the end of 2025, this reservation allowed a distinction between standardised software and customised software for the taxation of royalties.<\/em><\/span><\/p>\n

\u25a2<\/span> The impact of new guidance to Slovak business<\/strong><\/p>\n

From 1 January 2026, payments for the right to use any software, including customised or non-standard software, are treated as \u201croyalties\u201d for withholding tax purposes in Slovakia<\/strong>.<\/p>\n

This applies even where there is no full transfer of ownership rights<\/u> and the customer receives only the right to use the software. Such payments may therefore be taxed under the applicable double tax treaty.<\/p>\n

This means:<\/p>\n