The Slovak Republic’s Finance Ministry launched a consultation on Draft Law No. LP/2026/369 to amend Act No. 507/2023 Coll. with OECD minimum tax adjustments, including extended safe harbours for country-by-country reporting, protections for local tax incentives, and clarified obligations for dissolved companies, with consultation closing 15 July 2026.

The Slovak Republic’s Ministry of Finance has launched a consultation on the Draft Law No. LP/2026/369 amending Act No. 507/2023 Coll., which implemented the EU Minimum Taxation Directive. The proposed amendments aim to incorporate adjustments arising from the OECD/G20 Inclusive Framework’s Side-by-Side Package on global minimum tax rules, confirmed by the European Commission on 12 January 2026.

The OECD announced on 5 January 2026 that the 147 members of the OECD/G20 Inclusive Framework on BEPS agreed on key elements of a side-by-side arrangement, including two safe harbours for multinational enterprise groups headquartered in jurisdictions with eligible tax regimes.

Act No. 507/2023 regarding a top-up tax designed to ensure a minimum level of taxation for large multinational and domestic groups. This legislation establishes a 15% minimum tax rate to align with global standards, targeting corporate entities with annual revenues exceeding EUR 750 million.

The Act also specifies methods for determining adjusted covered taxes and the proper allocation of income between parent companies and their subsidiaries. This legal framework serves as the basis for implementing qualified domestic minimum top-up tax rules within Slovakia.

The key details of the amending Act No. 507/2023 Coll. are as follows:

Additional time for simplified reporting (“Safe Harbour” extension)

The current law gives companies a temporary “grace period” (a safe harbour) where they can use simplified country-by-country reports to avoid doing highly complex top-up tax calculations. Currently, this break is set to expire for accounting periods starting after 31 December 2026.   The draft law extends this grace period by one year. It also confirms that a special transitional tax rate of 17%, which is already written into the law for the year 2026, will continue to apply during this extended period.

Protecting real local investments (Economic substance)

The existing law already lowers a company’s minimum tax burden if they have a real physical presence in Slovakia—specifically, by looking at how much they spend on local employee payroll and physical assets like buildings, machines, and equipment. The proposed update introduces a new, specific exemption to protect local tax incentives that are tied to this genuine business activity. It ensures that when Slovakia gives a company a tax break for creating real jobs and building infrastructure, the global minimum tax doesn’t accidentally cancel that benefit out.

Closing a loophole for shut-down companies

The current law defines exactly who is considered a taxpayer and how the tax is administered. However, it lacks a specific rule for what happens to a company’s tax bill if the business simply ceases to exist without leaving a legal successor behind. The new update creates a clear rule to seamlessly transfer the closed company’s tax obligations to another entity. This ensures that the responsibility to pay any owed minimum tax doesn’t just disappear when a company closes its doors.

The proposed amendments are expected to take effect on 31 December 2026, with the exception of the extension of the CbCR safe harbour, which is scheduled to apply from 30 December 2026.

The consultation on Draft Law No. LP/2026/369 runs until 15 July 2026, after which the law must pass parliamentary approval and presidential signature before entering into force.