Slovak Republic

Corporate - Withholding taxes

Last reviewed - 04 February 2020

Mainly, the following payments are subject to WHT when made by Slovak companies to foreign parties. According to the amendment of the Income Tax Act, effective from 1 January 2017, dividends will also be subject to WHT. However, a DTT may reduce or eliminate the rate.

Payments WHT (%)
Fees for services 19/35
Royalties * 19/35
Interest on loans and deposits * 19/35
Dividends ** 7/19/35


* Royalties and interest paid to related EU-resident companies are not subject to WHT if certain conditions are met.

** Dividends paid out of profits arising from 2004 to 2016 are not subject to Slovak WHT (subject to anti-avoidance provisions). Please see Dividend income in the Income determination section.

A 35% WHT rate applies on payments to taxpayers from non-contracting states (i.e. states that did not conclude either a DTT or TIEA with the Slovak Republic) or where the beneficial owner of the income is not (cannot be) identified.

Service fees may be subject to tax in Slovakia only if the service is provided in the territory of Slovakia or if paid for by a Slovak tax resident.

WHT should be paid to the Tax Office no later than 15 days from the end of the calendar month following that in which the payment was made. The withholding obligation lies with the Slovak resident taxpayer. The taxpayer must also notify the tax administrator of the tax withheld and transferred. If the tax is not properly withheld, the unpaid tax becomes the Slovak tax resident’s tax liability, and a penalty may be assessed.

This table highlights countries with which Slovakia has entered into a DTT.

Recipient WHT (%)
Dividends (24) Interest Royalties
Armenia 5/10 10 5
Australia 15 10 10
Austria 10 0 5
Belarus 10/15 10 5/10 (1)
Belgium 5/15 10 5
Bosnia and Herzegovina 5/15 0 10
Brazil 15 10/15 (2) 25/15 (3)
Bulgaria 10 10 10
Canada 5/15 10 10 (4)
China, People’s Republic of 10 10 10
Croatia 5/10 10 10
Cyprus 10 10 5
Czech Republic 5/15 0 10
Denmark 15 0 5
Estonia 10 10 10
Finland 5/15 0 0/1/5/10 (5)
France 10 0 0/5 (6)
Georgia 0 5 5
Germany 5/15 0 5
Greece Domestic (7) 10 10
Hungary 5/15 0 10
Iceland 5/10 0 10
India 15/25 15 30
Indonesia 10 10 10/15 (8)
Iran 5 5 7,5
Ireland 0/10 0 10
Israel 5/10 2/5/10 (9) 5
Italy 15 0 0/5 (10)
Japan 10/15 10 0/10 (11)
Kazakhstan 10/15 10 10
Korea, Republic of 5/10 10 10
Kuwait 0 10 10
Latvia 10 10 10
Libya 0 10 5
Lithuania 10 10 10
Luxembourg 5/15 0 0/10 (12)
Macedonia (North Macedonia) 5 10 10
Malaysia 0/5 10 10
Malta 5 (13) 0 5
Mexico 0 10 10
Moldova 5/15 10 10
Montenegro 5/15 10 10
Netherlands 0/10 0 5
Nigeria 12.5/15 15 15
Norway 5/15 0 0/5 (14)
Poland 0/5 5 5
Portugal 10/15 10 10
Romania 10 10 10/15 (15)
Russia 10 0 10
Serbia 5/15 10 10
Singapore 5/10 0 10
Slovenia 5/15 10 10
South Africa 5/15 0 10
Spain 5/15 0 5
Sri Lanka 15 0/10 (16) 0/10 (17)
Sweden 10 0 5
Switzerland 0/15 0/5 (18) 0/10 (19)
Syria 5 10 12
Taiwan 10 10 5/10 (20)
Tunisia 10/15 12 5/15 (21)
Turkey 5/10 10 10
Turkmenistan 10 10 10
Ukraine 10 10 10
United Arab Emirates 0 10 10
United Kingdom 5/15 0 0/10 (22)
United States 5/15 0 0/10 (23)
Uzbekistan 10 10 10
Vietnam 5/10 0/10 5/10/15 (24)

Notes:

  1. The 5% rate applies to literary, artistic, and scientific work including cinematohraph films or films, tapes and other means of image or sound reproduction. The 10% rate applies in other cases.
  2. The 10% rate applies to industrial and public works equipment loans granted by a bank for a period of at least 10 years. The 15% rate applies in other cases.
  3. The 25% rate applies to trademark royalties. The 15% rate applies in other cases.
  4. The reduced WHT rate applies to artistic copyright royalties but not including royalties for motion picture films.
  5. The 0% rate applies to literary, artistic, and scientific work copyright royalties. The 1% rate applies to finance leases of equipment. The 5% rate applies to operating leases of equipment, film, and broadcasting royalties, and to computer software royalties. The 10% rate applies to patent, trademark, design or model, plan, secret formula.
  6. The 0% rate applies to literary, artistic, and scientific work copyright royalties. The 5% rate applies in other cases.
  7. The source state may tax the income at its domestic rate.
  8. The 10% rate applies to film and broadcasting royalties. The 15% rate applies to copyright, patent, software, trademark royalties, and to industrial, commercial, and scientific equipment and information royalties.
  9. The 2% rate applies to government debt or government-assisted debt, the 5% rate applies when the recipient is a financial institution, and the 10% rate applies in other cases.
  10. The 0% rate applies to copyright royalties. The 5% rate applies in other cases.
  11. The 0% rate applies to cultural royalties and the 10% rate applies to industrial royalties.
  12. The 0% rate applies to royalties and other similar fees received by a resident as a member of a board of directors or another similar body. The 10% rate for licence fee applies to other cases.
  13. See the treaty for applicability of rates.
  14. The 5% rate applies to patent and trademark royalties and to industrial, commercial, and scientific equipment royalties. The 0% rate applies to other cases.
  15. The 10% rate applies to patent and trademark royalties, and to information concerning, industrial, commercial, and scientific experience. The 15% rate applies in other cases.
  16. The 0% rate applies to interest received by a bank.
  17. The 0% rate applies to copyright royalties and the 10% rate applies in other cases.
  18. The 0% rate applies to the credit sale of equipment, merchandise, or services; a loan granted by a financial institution; a pension fund; or to interest paid by a company to a company of the other state that is affiliated with the company paying the interest by a direct minimum holding of 25% in the capital for at least two years prior to the payment of the interest or where both companies are held by a third company that has a direct a minimum holding of 25% for at least two years prior to the payment of the interest, both in the capital of the first company and in the capital of the second company. In other cases, the 5% rate applies.
  19. The 0% rate applies to copyright royalties for literary, artistic, or scientific work, including cinematograph films or films or tapes. The 10% rate applies to patent and trademark royalties and to industrial, commercial, and scientific information royalties. However, patent and trademark royalties and industrial, commercial, and scientific information royalties are taxable at 0% if paid by a company resident in a state to a resident of the other state where the beneficial owner is a company that is affiliated with the company paying the royalties by a direct minimum holding of 25% in the capital for at least two years prior to the payment of the royalties or where both companies are held by a third company that has a direct minimum holding of 25% for at least two years prior to the payment of the royalties, both in the capital of the first company and in the capital of the second company.
  20. The 5% rate applies to industrial, commercial, or scientific equipment royalties. The 10% rate applies in other cases.
  21. The 5% rate applies to literary, artistic, and scientific works copyright royalties. The 15% rate applies in other cases.
  22. The 0% rate applies to literary, artistic, and scientific works copyright royalties. The 10% rate applies in other cases.
  23. The 0% rate applies to literary, artistic and scientific works copyright royalties. The 10% rate applies in other cases.
  24. The 5% rate applies to patent and secret formula royalties; industrial and scientific information royalties; and industrial, commercial, and scientific equipment royalties. The 10% rate applies to trademark royalties and commercial information royalties. The 15% rate applies in other cases. The lower rate applies if the recipient is a company that directly owns at least a certain amount of the capital or a cert