The Slovak Republic’s Ministry of Finance has announced plans to draft an amendment to Law No. 507/2023, enacted on 8 December 2023.
This law partially implemented the Pillar Two global minimum tax in alignment with Council Directive (EU) 2022/2523 of 14 December 2022.
The amendments will include OECD guidance and update the Directive on administrative cooperation in taxation (Directive 2011/16/EU) to simplify filing obligations under the Pillar Two Directive (DAC9).
DAC lays down the rules and procedures for EU countries’ tax authorities to closely cooperate with each other in direct taxation. It sets up a harmonised framework allowing EU countries to help each other by sharing information and through other forms of advanced cooperation.
The DAC9 proposal is closely linked with the 2022 Pillar Two Directive, which aims to ensure a global minimum level of taxation for multinational enterprise groups (MNEs) and large-scale domestic groups (LSDGs) in the EU.
The DAC9 proposal supports the Pillar Two Directive by making it easier for MNEs to comply with their filing obligations under that Directive. Without the DAC9 proposal, each company that forms part of an MNE would have to file a top-up tax information return in the country where it is based, which can be time‑consuming and complicated.
Now, under DAC9, MNEs only have to file one top-up tax information return, at central level, for the entire group. This will significantly simplify the filing process and reduce the administrative burden for MNEs.
DAC9 is anticipated to receive approval by March 2025, after which the draft bill will be finalised.
Earlier, the Ministry of Finance has launched a public consultation on the draft bill No. LP/2024/645 on 25 November 2024, which concluded on 13 December 2024. This bill proposed amending the Act on the Automatic Exchange of Information on Financial Accounts for Tax Administration and related laws to implement the provisions of the Amending Directive to the 2011 Directive on Administrative Cooperation (2023/2226) (DAC8).
