During the summer break, we have summarized the most important updates and information regarding international taxation and developments in double taxation treaties. Below is a brief overview on this topic:
◻ Update to the Double Taxation Treaty between Slovakia and Brazil
The double taxation treaty between the Slovak Republic and Brazil has recently been updated to reflect current tax conditions in both countries, as the treaty had not undergone significant changes for a long period.
Selected measures from the G20/OECD BEPS Action Plan, aimed at combating base erosion and profit shifting, have also been incorporated. In addition, the update includes revised definitions and a new article on the exchange of information.
The following key areas of the treaty have been amended:
- new definitions and scope of covered taxes and persons
- methods for eliminating double taxation
- mutual agreement procedure and information exchange
- entitlement to benefits
The revised treaty was ratified by the President of the Slovak Republic on May 9, 2025. The full text of the Protocol amending the treaty is available at the following website.
◻ Update to the Double Taxation Treaty between Slovakia and Iran
The Slovak Republic and Iran have amended their double taxation treaty for the first time since it was signed in 2016. This marks a historic update, reflecting the ongoing trade relations between the two countries and efforts to modernize tax cooperation in line with global developments.
The amendments cover the following areas:
- Residency of the impacted persons and introduction of new definitions
- Clarifications on when a permanent establishment is not created
- Expansion of the articles likewise Business Profits and Associated Enterprises
- Revision of the article on the elimination of double taxation
- Changes to the articles on information exchange and limitation of benefits
These changes will come into force only after they are signed and ratified by the President of the Slovak Republic.
◻ Australia Amends Multilateral Instrument with Slovakia
The Australian Taxation Office has updated the text of its tax treaty with the Slovak Republic to reflect adjustments under the Multilateral Instrument (MLI). This includes modifications to references, official wording, and inserted articles (e.g., Article 5 of the treaty).
In addition to Slovakia, this update also affects Australia’s tax treaties with Denmark, Ireland, Norway, India, the Netherlands, and other countries.
These developments follow the recent progress in the area of double taxation treaty negotiations, which we have previously reported in our Moore BDR I News.
