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Forvis Mazars in Slovakia
Sky Park Offices 1,
Bottova 2A, 811 09 Bratislava
Slovakia
+421 259 204 700
 
+421 259 204 703
https://www.forvismazars.com/sk
Kvetoslava Čavajdová
Tax Partner
+421 259 204 700
kvetoslava.cavajdova@mazars.sk
DETAILED PROFILE

Slovakia

Corporate taxes and other direct taxes

The CIT rate in Slovakia is 21%. The 15% rate applies to taxpayers if their income does not exceed EUR 60,000/tax period. The tax base is calculated from accounting profit (loss) as modified by certain increasing and decreasing items. Starting from January 1, 2024 a minimum tax (340 to 3,840 EUR, depending on taxable income) will apply to legal entities that report a tax liability lower than the established amount.
Tax losses (reported since 2020) can be deducted for a maximum of five consecutive tax periods, up to 50% of the taxpayer’s tax base. 
There are several types of tax incentives potentially available, e.g. super-deduction of R&D costs, additional deduction of costs incurred for certain machinery and equipment linked to Industry 4.0 or tax exemption of part of income for granting the right to use a protected patent/ software created by the taxpayer.
Business restructuring (mergers, acquisitions, etc.) can be carried out solely at fair market values (in specific cases – historical value method available).
Participation exemption rules for capital gains on the sales of shares (ownership interest) can be applied under specific conditions.
Thin capitalization rules apply in Slovakia, extended by ATAD provisions as of January 1, 2024.

Withholding tax (under Slovak law)
- 0% on dividends if paid to a company that is a tax resident of ‘cooperative jurisdiction’ and the beneficial owner has a dividend income;
- 19% on interest, royalties, bonuses, income of authors of articles, etc.;
- 35% on payments to a resident of a non-cooperative country not included in the list issued by the Slovak Ministry of Finance (e.g. country that has neither a DTT nor a treaty on tax information exchange with Slovakia), or where the beneficial owner cannot be proven;
Interests and royalties paid by Slovak tax residents to related EU entities – exempt from tax (specific rules apply).
WHT may be reduced by provisions of applicable DTT (currently, DTTs have been concluded with 70 jurisdictions).

Real estate tax is imposed on real estate owners based on the type of property – land, buildings and apartments. The ax liability is calculated by the municipal authorities and depends on various factors (e.g. location, area, etc.).
Motor vehicle tax is imposed on the user/owner of the motor vehicle used for business purposes. Tax rates differ based on technical parameters.
Other taxes: insurance tax, special levy in regulated industries.

Transfer pricing in Slovakia
Arm's length principle Since 1999
Documentation liability Since 2009
APA Since 2004
Country-by-Country liability
from FY 2016 
Master file-local file (OECD BEPS 13) applicable Applicable for specific taxpayers 
Penalty    
- lack of documentation

up to EUR 3,000 / missing documentation (recurrent basis)

- tax shortage

13.5% p.a. of tax underpayment (up to 100% of the underpayment) / 27% in case of aggressive tax planning in transfer pricing

Related parties > 25%

Direct or indirect control
or common managing director, close relatives or other control aimed purely on circumvention of tax.

Safe harbors   No transfer pricing rules applied on transactions below EUR 10,000 or EUR 50,000 in case of loans. The evaluation of the above threshold is more complex (i.e. the tax value of transactions from both related parties have to be considered).

Level of attention paid by Tax Authority:

9/10

VAT and other indirect taxes

The basic VAT rate is 20%. The reduced rate of 10% applies e.g. to accommodation services, restaurant and catering services (excluding alcohol), services for the purpose of performing sport in indoor and outdoor sports facilities, pharmaceutical products, books, lenses, basic food items (e.g. bread, butter, milk), some periodicals, healthy foodstuffs (e.g. dairy products), honey, and most vegetables and fruits. The reduced VAT rate of 5% applies to the provision of buildings, including land for building, which meets the conditions of state-supported residential rental housing.
A special voluntary arrangement based on the receipt of payment for goods and services (so-called “cash accounting”) can be applied by certain VAT payers.
VAT payers are obliged to report to the Slovak Tax Authorities all bank accounts used for economic activities that are subject to VAT. Payment of the supplier’s invoice to a bank account which was not listed at the time of payment may lead to application of joint liability for VAT.
The possibility exists to correct the tax base from the supply of goods or services if the taxpayer didn't receive a payment and its receivable has become uncollectable. 
As of January 1, 2023, customers are obliged to correct the deducted input VAT from purchased goods or services if they do not partially or fully settle the liability within 100 days of the due date.

Other indirect tax types in Slovakia include excise taxes on wine, beer, tobacco, spirits, mineral oils, electricity, coal, and natural gas.

VAT options in Slovakia Applicable / limits
Distance selling The OSS system is applicable from July 1, 2021.
Call-off stock
VAT group registration
Cash accounting - yearly amount in EUR (approx.)* Approx. EUR 100,000/year
Import VAT deferment
Local reverse charge Construction works; deliveries of goods and certain types of services in Slovakia by a taxable person who is not established in Slovakia (foreign VAT payers); sale of waste, specific metal products, emission quotas; sale of agricultural products; sale of specific electronic devices, etc.
Option for taxation
- letting of real estate
- supply of used real estate
VAT registration threshold* EUR 49,790

Personal income tax / Social security system

The PIT rate is progressive and depends on the amount of income earned. The PIT rate is 19% for a tax base up to EUR 47,537.98/year (for 2024) and 25% for amounts exceeding this limit. Certain tax allowances (e.g. personal, spouse allowance, tax bonus for children) may be claimed on personal income.
The 15% tax rate applies to natural persons achieving income from entrepreneurial (other self-employed) activities, provided their income does not exceed EUR 60,000/year.
Dividends (from profit generated after January 1, 2024) and some other income (e.g. share in the liquidation balance of the company/cooperative, the settlement share, etc.) are subject to taxation at 10% (capped by DTT for non-residents) or at 35% if the recipient or payer of the dividends is from a 'non-cooperative' jurisdiction. 

Both employers and employees are subject to social security and health insurance contributions on the employee's gross monthly salary. The rates are 36.2% for employers (25.2% social security and 11% health insurance) and 13.4% for employees (9.4% social security and 4% health insurance). Social security contributions are capped by a maximum assessment base of EUR 9,128 (in 2024). There is no maximum assessment base for health insurance contributions. A health insurance allowance (annually up to EUR 4,560) can be applied by low-income employees for employee contributions.
As of January 1, 2023, a minimum health insurance contribution has been introduced, being EUR 40.32/month for employees (in 2024).

Wage related taxes
in Slovakia
Minimum wage Average wage*** in private sector
  in EUR   in EUR**  
  750   1,383  
Total wage cost 1,022 136.20% 1,884 136.20%
Vocational training contribution  -   -  
Social security and health insurance contributions (Employers' part) 272 36.20% 501 36.20%
Gross salary 750 100.00% 1,383 100.00%
Personal income tax* 123 19.00% 228 19.00%
Employees' contributions 101 13.40% 185 13.40%
Net salary 526 67.60% 970 67.60%

* The gross salary could be decreased by social security and health insurance contributions (employee's part) and personal allowance (EUR 470.54 EUR/month in 2024 - not considered above).
** average for 1st-3rd quarter 2023
*** the wage from regular employment contract