Page 50 - CEE Tax Guide 2025

Slovakia

Forvis Mazars Tax k.s.
SKY PARK OFFICES 1,
Bottova 2A811 09 Bratislava,
Slovakia
Phone: +421 259 204 700
www.forvismazars.com/sk

Corporate taxes and other direct taxes There are several types of tax incentives
potentially available.
The CIT rate in Slovakia is 21%. The 15% applies Business restructuring (mergers, acquisitions, etc.)
to taxpayers for 2024 if their income does not can be carried out solely at fair market values.
exceed EUR 60,000/tax period. Starting from 2025 Participation exemption rules for capital gains
tax periods, the CIT rate for taxpayers whose taxable on the sales of shares (ownership interest) can
income (revenues) exceeds in tax period 5 million be applied under specific conditions.
EUR will increase to 24% and decrease from 15%
to 10% if taxable income does not exceed EUR Withholding tax (under Slovak law):
100,000 (small and medium-sized enterprises). • 0% on dividends if paid to a company that is a tax
A minimum tax (340 to EUR 3,840, depending resident of ‘cooperative jurisdiction’ and the
on taxable income) applies to legal entities that beneficial owner of a dividend income;
report a tax liability lower than the established • 19% on interest, royalties, income of authors
amount. Tax losses can be deducted for a maximum of articles, etc.:
of five consecutive tax periods, up to 50% of the • 35% on payments to a resident of a non-
taxpayer’s tax base.
cooperative country not included in the list
issued by the Slovak Ministry of Finance (e.g.
Transfer pricing in Slovakia country that has neither a DTT nor a treaty on tax
Arm’s length principle Since 1999 information exchange with Slovakia), or where
the beneficial owner cannot be proven;
Documentation liability Since 2009
Interests and royalties paid by Slovak tax residents
APA Since 2004
to related EU entities – exempt from tax (specific
Country-by-Country From FY 2016 rules apply).
liability WHT may be reduced by provisions of applicable

Master file-local file Applicable for DTT (currently, DTTs have been concluded with
(OECD BEPS specific taxpayers. 75 jurisdictions).
13) applicable
Real estate tax is imposed on real estate owners
Penalty based on the type of property – land, buildings
and apartments. The tax liability is calculated
lack of documentation Up to EUR 3,000 /
missing documentation by the municipal authorities and depends
(recurrent basis). on various factors.
Motor vehicle tax is imposed on the user/owner
tax shortage 10% p.a.
of tax underpayment of the motor vehicle used for business purposes. Tax
(up to 100% of the rates differ based on technical parameters.
underpayment).
Other taxes: insurance tax, special levy in regulated
Related parties 25% < Direct or indirect industries, tax from financial transactions.
control, common
managing director, close
relatives, etc. VAT and other indirect taxes
Safe harbors Transactions below The basic VAT rate is 23%. The reduced rate of 5%
EUR 10,000/ EUR 50,000 applies e.g. to selected basic foods (meat, milk,
in case of loans.
sour cream, potatoes, bakery products and others),
Level of attention paid 9/10 medicines, pharmaceutical products, medical
by Tax Authority supplies, books, accommodation services, books

Central and Eastern European tax guide 2025 Forvis Mazars 50