Page 48 - Mazars Central and Eastern European tax guide 2023

Slovakia A special voluntary arrangement based on the receipt if the customer does not partially or fully settle the liability
of payment for goods and services (so-called “cash
within 100 days of its due date.
accounting”) can be applied by certain VAT payers. Other indirect tax types in Slovakia include excise taxes
VAT payers are obliged to report all bank accounts used for on wine, beer, tobacco, spirits, mineral oils, electricity, coal
economic activities that are subject to VAT to the Slovak and natural gas.
Tax Authorities. Payment of the supplier’s invoice to a bank
Mazars Tax k.s. account which was not listed at the time of payment may lead Personal income tax / Social security system
SKY PARK OFFICES 1, to application of joint liability for VAT.
Bottova 2A The possibility exists to correct the tax base from the supply The PIT rate is progressive and depends on amount
811 09 Bratislava of goods or services if the taxpayer didn't receive a payment of income earned. The PIT rate is 19% for a tax base
Phone: +421 259 204 700 and its receivable has become uncollectable. up to EUR 41,445.46/year (for 2023) and 25% for amounts
Fax: +421 259 204 703 As of 1 January 2023, the customers are obliged to correct exceeding this limit. Certain tax allowances (e.g., personal,
www.mazars.sk spouse allowance, tax bonus for children) may be claimed
the deducted input VAT from purchased goods or services,
on personal income.
The 15% tax rate applies to natural persons achieving income
VAT options in from entrepreneurial (other self-employed) activities,
Corporate taxes and other direct taxes Business restructuring (mergers, acquisitions, etc.) can Slovakia Applicable / limits provided their income does not exceed EUR 49,790/year.
be carried out solely at fair market values (in specific cases Dividends (from profit generated after 1 January 2017) and
The corporate income tax rate in Slovakia is 21%. The 15% – historical value method available). From 1 July 2021 OSS system some other income (e.g., share in the liquidation balance
tax rate applies for taxpayers if their income does not Participation exemption rules for capital gains on sales Distance selling is applicable. of the company/cooperative, the settlement share, etc.) are
exceed EUR 49,790/tax period. The tax base is calculated of shares (ownership interest) could be applied under subject to taxation at 7% (capped by DTT for non-residents)
from accounting profit (loss) as modified by certain specific conditions. Call-off stock ü or at 35% if the recipient or payer of the dividends is from
increasing and decreasing items. Thin capitalization rules apply in Slovakia, to be extended VAT group registration ü 'non-cooperative' jurisdiction.
Tax losses incurred in the tax periods starting from by ATAD provisions as of 1 January 2024. Cash accounting – yearly approx. EUR 100,000/year Income attributable from controlled foreign companies (CFC)
1 January 2020 can be deducted for a maximum of five Withholding tax (under Slovak law) amount in EUR (approx.) is taxed at 25% in hands of natural persons.
consecutive tax periods, up to 50% of taxpayer’s tax base. • 0% on dividends if paid to company that is a tax Import VAT deferment No Both employers and employees are subject to social
There are several types of tax incentives potentially resident of ‘cooperative jurisdiction’ and the beneficial Construction works; deliveries security and health insurance contributions on the
available, e.g., super-deduction of R&D costs, additional owner of dividend income; of goods and certain types of services employee's gross monthly salary. The rates are 35.2% for
deduction of costs incurred for certain machinery and • 19% on interest, royalties, prizes, income of authors for in Slovakia by a taxable person who employers (social security 25.2% and health insurance 10%)
equipment linked to Industry 4.0 or tax exemption of part articles, etc.; Local reverse charge is not established in Slovakia (foreign and 13.4% for employees (social security 9.4% and health
VAT payers); sale of waste, specific
of income for granting the right to use a protected patent/ • 35% on payments to a resident of a non-cooperative metal products, emission quotas; sale insurance 4%). Social security contributions are capped
software created by the taxpayer. of agricultural products; sale of specific by a maximum assessment base of EUR 8,477 (in 2023).
country not included in the list issued by the Slovak There is no maximum assessment base for health insurance
Ministry of Finance (e.g., country that has neither a DTT electronic devices, etc. contributions. A health insurance allowance (annually

Transfer pricing in Slovakia nor a treaty on tax information exchange with Slovakia), Option for taxation up to EUR 4,560) can be applied by low-income employees
or where the beneficial owner cannot be proved; letting of real estate ü
Arm’s length principle ü Since 1999 Interests and royalties paid by Slovak tax residents supply of used real estate ü on employee contributions.
As of 1 January 2023, a minimum health insurance
Documentation liability ü Since 2009 to related EU entities – exempt from tax (specific VAT registration EUR 49,790 contribution has been introduced, being EUR 32.81/month
rules apply). threshold
APA ü Since 2004 The WHT may be reduced by provisions of applicable for employees (in 2023).
Country-by-Country from FY 2016 DTT (currently, DTTs have been concluded with
liability ü 70 jurisdictions). Wage related taxes in Slovakia Minimum wage Average wage***
Master file-local file Real estate tax is imposed on real estate owners based in private sector
(OECD BEPS 13) ü Applicable for specific on the type of property – land, buildings and apartments. in EUR in EUR**
taxpayers.
applicable Tax liability is calculated by the municipal authorities and
Penalty depends on various factors (e.g., location, area, etc.). 700 1,296
up to EUR 3,000 / missing Motor vehicle tax is imposed on user/owner of motor Total wage cost 946 135.20% 1,752 135.20%
lack of documentation ü documentation vehicle used for business purposes. Tax rates differ based
(recurrent basis) on technical parameters. Vocational training contribution – –
10% p.a. of tax underpayment Social contribution tax 246 35.20% 456 35.20%
tax shortage ü or 20% in case of aggressive tax Other taxes: insurance tax, special levy in regulated
planning in transfer pricing industries. Gross salary 700 100.00% 1,296 100.00%
Direct or indirect control Personal income tax* 115 19.00% 213 19.00%
or common managing VAT and other indirect taxes
Related parties 25% < director, close relatives Employees' contributions 94 13.40% 174 13.40%
or other control aimed purely The basic VAT rate is 20%. The reduced rate at 10% applies, Net salary 491 67.60% 909 67.60%
on circumvention of tax. e.g., to accommodation services, pharmaceutical products,
No transfer pricing rules books, lenses, basic food items (e.g., bread, butter, milk), * The gross salary could be decreased by social security and health insurance contributions (employee's part) and personal allowance (EUR 410.24 EUR/month in 2023 - not considered above).
applied on transactions below some periodicals, healthy foodstuffs (e.g., dairy products), ** For 3 rd quarter 2022.
*** The wage from regular employment contract.
EUR 10,000 or EUR 50,000
in case of loans. The evaluation honey, most of vegetables and fruits. In 1Q 2023, the reduced
Safe harbours of the above threshold rate will also apply to certain sports services (e.g., ski lifts,
is more complex (i.e., tax value swimming pools) and to restaurant/ catering services. Kvetoslava Čavajdová
of transaction from both related Partner
parties have to be considered). As of 1 January 2023, the reduced VAT rate of 5% applies Phone: +421 259 204 700
Level of attention paid by Tax on supply of a building, including building land, which meets E-mail: kvetoslava.cavajdova@mazars.sk
Authority 9/10 the conditions of state-supported rental housing.

48 Mazars Central and Eastern European tax guide 2023 Central and Eastern European tax guide 2023 Mazars 49