Slovak Republic

Mainly, the following payments are subject to WHT when made by Slovak companies to foreign parties. Dividends are also subject to tax, effective as of 1 January 2017 (subject to specific rules). However, a DTT may reduce or eliminate the rate.

* 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 Corporate Income determination and Individual Income determination sections.

A 35% WHT rate applies on payments to taxpayers from non-cooperative jurisdictions (i.e. where no DTT or TIEA exists, the taxpayer is from a jurisdiction that is listed in the EU's List of Non-Cooperating Countries or a state that does not apply CIT, or a zero CIT rate applies) or where the beneficial owners of the income 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.

Notes

1. The 5% rate applies to the use of, or the right to use, any patent, trademark, design or model, plan, secret formula or process, software, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience. The 10% rate applies to any copyright of literary, artistic, or scientific work, including cinematograph films or films or tapes and other means of image or sound reproduction.
2. The 5% rate applies to any copyright of literary, artistic, or scientific work, including cinematograph films or films or tapes and other means of image or sound reproduction.
3. The 10% rate applies in respect of interest from loans and credits granted by a bank for a period of at least ten years in connection with the selling of industrial equipment or with the study, the installation, or the furnishing of industrial or scientific units, as well as with public works; and the 15% rate applies in other cases.
4. The 25% rate applies to trademark royalties, and the 15% rate applies in other cases.
5. The reduced WHT rate applies to artistic copyright royalties.
6. The 5% rate applies to industrial, commercial, or scientific equipment royalties. The 10% rate applies in other cases.
7. 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 and trademark royalties and to information concerning industrial, commercial, and scientific experience.
8. The 0% rate applies to literary, artistic, and scientific work copyright royalties, and the 5% rate applies in other cases.
9. The source state may tax the income at its domestic rate.
10. The 15% rate applies to copyright, patent, software, and trademark royalties, and to industrial, commercial, and scientific equipment and information royalties. The 10% rate applies to film and broadcasting royalties.
11. The 0% rate applies to literary, artistic, and scientific work copyright royalties. The 10% rate applies in other cases.
12. 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.
13. The 0% rate applies to copyright royalties. The 5% rate applies in other cases.
14. The 0% rate applies to cultural royalties, and the 10% rate applies to industrial royalties.
15. The 0% rate applies to interest paid in connection with the sale on credit of any industrial, commercial, or scientific equipment, or paid in connection with the sale on credit of any merchandise by one enterprise to another enterprise. The 10% rate applies in other cases.
16. The 0% rate applies to literary, artistic, and scientific work copyright royalties. The 10% rate applies in other cases.
17. The 0% rate applies to copyright related to any work of art, literature, or science, including cine films and films and recordings for radio and television broadcasting. The 10% rate applies in other cases.
18. See the treaty for applicability of rates.
19. The 5% rate applies to patent and trademark royalties and to industrial, commercial, and scientific equipment royalties.
20. 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.
21. The 0% rate applies to copyright royalties. The 5% rate applies in other cases.
22. The 0% rate applies to interest received by a bank.
23. The 0% rate applies to copyright royalties, and the 10% rate applies in other cases.
24. The 0% rate applies to literary, artistic, and scientific work copyright royalties. The 5% rate applies in other cases.
25. 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.
26. 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.
27. The 5% rate applies to literary, artistic, and scientific work copyright royalties, and the 15% rate applies in other cases.
28. The 0% rate applies to literary, artistic, and scientific work copyright royalties, and the 10% rate applies in other cases.
29. The 0% rate applies to copyright royalties. The 10% rate applies in other cases.
30. 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.