Slovak Republic

Based on the amendment of the Income tax Act (ITA), valid as of 18 April 2023, the withholding taxation of interest and other income from the commercial corporate bonds issued by Slovak issuers has been abolished. Interest and other income from the commercial corporate bonds were subject to the Slovak withholding tax (WHT) from 1 January 2023 to 17 April 2023. 

Also, it is anticipated, that European Union (EU) Directive on a global minimum level of taxation will be transposed to the Slovak legislation by the end of 2023. According to the issued draft legislation, Slovakia would introduce only the qualified domestic minimum top-up tax (QDMTT), applicable form 1 January 2024.

Additionally, the spin-off concept has been introduced into the Slovak commercial law along with the relevant tax provisions. The relevant legislative provisions will take effect from 1 March 2024. Generally, the tax rules for spin-offs follows the already existing tax rules for mergers and demergers, i.e. the transaction should be done at fair market value in the majority of cases.

Note that the tax legislation in the Slovak Republic (Slovakia) is subject to frequent amendments and new official interpretations; consequently, it is advisable to contact PwC Slovakia for up-to-date information.