Slovak Republic

Corporate - Corporate residence

Last reviewed - 10 February 2022

A company is a tax resident in the Slovak Republic if:

  • it has its registered seat
  • effective place of management in the Slovak Republic, where the key management decisions are made or accepted or
  • is not considered a tax resident in another contractual country according to the respective double tax treaty.

Permanent establishment (PE)

A PE is created if:

  • a foreign entrepreneur uses, either continually or repeatedly, a permanent place or facility for carrying out its business activities in Slovakia
  • a foreign entrepreneur repeatedly mediates transportation and accommodation services, including via a digital platform
  • an individual acting on behalf and in the name of a foreign entrepreneur repeatedly mediates or plays a leading role in concluding contracts or negotiating contract details, or
  • the period of providing services by the foreign entrepreneur or by individuals working for this foreign entrepreneur in Slovakia is longer than 6 months in any consecutive 12-month period.

The conditions for creating a PE may be regulated in more detail by a DTT.

A PE need not be entered in the Slovak Commercial Register, but a foreign entrepreneur with a Slovak PE is taxable in Slovakia. A foreign entrepreneur with a Slovak PE has the same tax registration, filing, payment, and tax advance payment obligations as a Slovak company. The tax base of a PE may not be less than one that which would have been achieved if similar activities under similar conditions were performed as an independent entity (e.g. a Slovak company).