Slovak Republic

Taxable period

The standard fiscal year is a calendar year, but a Slovak entity may opt to change this to a different 12-month period.

Tax returns

A corporate tax return must be filed together with the entity’s financial statements within three months following the fiscal year-end. The taxpayer may extend the filing deadline by up to three months or six months (in case foreign income is included in the tax return). To extend the filing deadline, the taxpayer must notify the Tax Office before the normal filing deadline. After notification, the deadline is automatically extended.

Payment of tax

The balance of tax due for a fiscal year is payable by the filing deadline.

Advance payments of corporate tax must be paid monthly or quarterly during the current tax period. Instalments are usually based on the last known tax liability of the entity. It is not necessary to pay tax advances if the last tax liability did not exceed EUR 2,500.

As of 1 January 2020, companies are required to pay tax advances only if their last tax liability exceeds EUR 5,000.

Starting from 1 January 2022, the tax administrator will notify a taxpayer who submitted a tax return of the amount and the due date for payment of the income tax advance no later than five days before its due date.

As of 1 January 2022, the tax reliability index is introduced, which represents the evaluation of a taxpayer regarding their ability to fulfil certain tax responsibilities towards the tax administrator. The taxpayer considered as reliable shall have specific tax benefits.

Penalties

The penalties levied by the Tax Office will depend on the time elapsed from the deadline for filing the regular tax return to the date of filing the amended tax return or the start of the tax audit. As the interest rate of the European Bank increased from 21 June 2023, the tax penalties were increased accordingly:

• From 3% to 4% a year for self-assessment via an amended tax return.
• From 7% to 8% a year for self-assessment within 15 days after notification that a tax audit has been opened (‘self-disclosure’).
• From 10% to 12% a year for an assessment made by the Tax Office during a tax audit.

The penalties will be levied at a minimum of 1% of the assessed amount and a maximum of 100% of the assessed amount.

An ‘aggregated penalty’ applies for cases of more than one administrative offence.

Electronic communication obligations

As of 1 January 2018, all legal entities registered in the Commercial Register are required to deliver submissions to the Financial Administration electronically only.

Tax audit process

Generally, the tax authority selects the taxpayers subject to tax audit based on certain criteria that are not communicated to the public.

The taxpayers that utilise state aid in the form of tax relief are subject to specific tax audit in the year of utilisation of the tax relief.

The tax audit has to be finalised within one year.

Statute of limitations

A tax may not normally be assessed or additionally assessed more than five years (ten years when DTT treaty was applied, including transactions with foreign-related parties) after the end of the year during which the obligation to file a tax return arose, or during which the taxpayer was obligated to pay the tax. If a tax inspection is undertaken within this five-year period, another five-year period commences from the end of the year in which the taxpayer was notified of this action.

If a taxpayer utilises a tax loss, a tax or additional tax cannot be assessed more than seven years after the end of the year in which the obligation to file a tax return in which a taxpayer reported the tax loss arose.

However, tax may be assessed, or additionally assessed, no later than ten years after the end of the year during which the obligation to file a tax return arose, or during which the taxpayer was obligated to pay the tax.

Topics of focus for tax authorities

The tax authorities, within a tax inspection, generally focus on transfer pricing, VAT, limited tax deductibility of special types of costs (e.g. entertainment, promotion costs), and tax incentives.