Last reviewed 08 Dec 2023
Income
10%
Corporate income tax rate for corporations with unlimited or limited liability to tax with taxable income (revenues) not exceeding the amount of EUR 100,000.00
21 %
Corporate income tax rate for corporations with unlimited or limited liability to tax with taxable income (revenues) exceeding the amount of EUR 100,000 but not exceeding EUR 5 million.
24%
Corporate income tax rate for corporations with unlimited or limited liability to tax with taxable income (revenues) exceeding the amount of EUR 5 million.
Minimum tax (between EUR 340 to EUR 3,840, depending on the value of the taxable income) applies to tax periods starting as of 1 January 2024.
Legal persons (a.s., j.s.a., s.r.o., v.o.s., k.s., cooperatives), branches and public sector institutions with their residence or management in Slovakia, on their world income
Foreign legal persons neither resident nor managed in Slovakia, on their Slovak income
Calendar year; different financial year possible, but must be reported to the tax office in writing in advance
Double-entry bookkeeping
No loss carryback
During consecutive 5 years and up to 50% of the tax base amount; in case of micro-taxpayers: during subsequent 5 years and up to the tax base amount
N/A
Expenses incurred to procure, secure or maintain business taxable income, and recorded in the tax- payer’s books and records; expenses with character of personal consumption spent also for private purposes are tax-deductible to a limited level, either in form of fixed expenses of 80 % or at documented level.
Arm’s length basis
In general, the following methods are employed:
Traditional transactional methods
Transactional profit methods
obligation to keep records of the method used
Interest on financing of acquisition of investment are treated as tax deductible at the time of further sale of shares under the condition the sale of shares will not be exempted from tax; exception for brokers
Interest from loans from related parties recognized as tax deductible only up to a limited amount of a maximum of 25 % of earnings before interest expenses, tax, depreciation and amortization (adjusted EBITDA); exception for leasing companies and financial institutions ("thin capitalisation restrictions"). New rules limiting the amount of tax deductible interest expense apply in Slovakia in case of loan contracts or amendments to already existing contracts concluded as of 2024 (for more information, please see section "EU interest barrier" below).
Seven depreciation categories
Tax depreciation may and in some cases has to be suspended;
component depreciation is possible
Advantageous depreciation of assets in Group 0-4 for micro-taxpayers
Group 0 - 2 years, green cars (electric and plug-in hybrid vehicles, bicycles and scooters with auxiliary electric motor);
Group 1 - 4 years, e.g. office equipment, cars, trucks, buses, telecom equipment;
Group 2 - 6 years, e.g. machines, furniture, special-purpose trucks, cranes;
Group 3 - 8 years, e.g. assets of technological nature (generators or transformers);
Group 4 - 12 years, e.g. small constructions, industrial machinery and – equipment, ventilation equipment, television and cable networks;
Group 5 - 20 years, production types of buildings – e.g. civil engineering, trade and services, industrial buildings;
Group 6 - 40 years, non- production types of buildings and constructions including hotels and administration buildings.
Provisions for untaken vacation including employer’s share of social insurance contributions, and for emissions are tax-deductible
Depreciation: 4 years
Acquisition cost as of: EUR 48,000 – restriction for tax depreciation
Income tax (including corporate income tax)
Distributions of profit
Expenses for personal use
Entertainment and promotional expenses including alcoholic drinks besides wine in certain cases (exception: promotional articles with an individual value of no more than EUR 17)
Expenses for unlawful activities
Donations except humanitary aid
Profit distributed to members of statutory bodies
Shortages and damages in excess of compensation received (theft, damage to the property: only those losses resulting from natural disasters and those caused by persons unknown and confirmed by a police report are recognized)
New rules limiting the amount of tax deductible interest expense apply in Slovakia in case of loan contracts or amendments to already existing contracts concluded as of 2024 (for more information, please see section "EU interest barrier" below).
For tax deductibility of inter-company interest and royalties expenses, general transfer pricing restrictions apply.
In case of inter-company interest expenses, also thin capitalisation restrictions apply (for more detail please see section "debt / equity" above).
Royalties are generally recognized as tax deductible only after payment.
Generally 19 %; a DTA can provide for a lower rate of taxation. Relief at the level of beneficial owner of the income is generally by (i) applying credit of tax withheld abroad or (ii) tax exemption of income already taxed abroad. Evidence of tax residence and beneficial ownership is required..
On payments to non-contracting states (e.g. off-shore countries) or when beneficial owner of the income cannot be proved, a withholding tax rate of 35 % applies.
At 19 %, or per applicable DTA; interest is are exempt from tax, if conditions of the EU Interest and Royalty Directive for group purposes are met (25 % minimum direct participation and 24 month minimum holding period, even if conditions are met additionally, after the day of income payment). This also applies where the interest is paid or finally received by a permanent establishment.
At 19 %, or per applicable DTA; royalties are exempt from tax, if the conditions of the EU Interest and Royalty Directive for group purposes are met (25 % minimum direct participation and 24 month minimum holding period, even if conditions are met additionally, after the day of income payment). This also applies where the royalty is paid or finally received by a permanent establishment.
This also applies where the royalty is paid or finally received by a permanent establishment.
Nil for distribution of profits generated for the years 2004 – 2016;
19 % on distributions of profits generated before 2004, unless DTA or the EU Parent-Subsidiary Directive for group purposes (25 % minimum direct participation, no minimum holding period) apply;
35 % on distributions of profits generated for the year 2017 and later if paid-out to non-contracting states or when beneficial owner of the dividend income cannot be proved.
Rules to prevent the erosion of tax bases and profit shifting by reattributing the income of a low-taxed controlled subsidiary or permanent establishments to its parent company are applicable.
Legislation include actions for prevention of:
N/A as distribution of profits generated for the year 2004 and later between Slovak companies is not subject to corporate income tax.
N/A
Please see section on "Withholding taxes - Dividends" above.
Goodwill can be amortized in statutory financial statements.
For tax purposes, goodwill can be amortized and considered in the taxation base over 7 consecutive years.
Not possible
N/A
N/A
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Opening Hours:
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Opening Hours:
Mo-Th: 08:00 – 17:00
Fr: 08:00 – 14:00
