The Slovak Ministry of Finance has proposed draft legislation to amend its top-up tax regime, expanding transitional and substance-based safe harbours, clarifying successor tax liabilities, and aligning domestic rules with the latest OECD Pillar Two guidance.
The Slovak Republic Ministry of Finance has proposed a draft amendment, on 18 August 2026, to Act No. 507/2023 Coll. pertaining to top-up tax, ensuring a global minimum level of taxation for multinational enterprise (MNE) groups and large-scale domestic groups operating in the jurisdiction.
Along with amending Act No. 507/2023 Coll., the draft also introduces modifications to Act No. 563/2009 Coll. on Tax Administration (Tax Code) and several other related regulations.
The original Act No. 507/2023 Coll. transposed Council Directive (EU) 2022/2523 of 15 December 2022. This directive was designed to establish a consistent, global minimum taxation standard across the European Union, utilising the global model rules (Pillar Two) adopted by the OECD/G20 Inclusive Framework on 14 December 2021.
Key updates include the extension of transitional safe harbours and the introduction of new tax exemptions tied to economic substance. Furthermore, the document addresses administrative continuity by defining how tax obligations are handled when a taxpayer ceases to exist without a legal successor.
Key technical amendments and safe harbours
This draft amendment introduces crucial updates to harmonise Slovak national law with the latest international guidelines on corporate taxation.
The measure expands the transitional “Safe Harbour” exemption, which permits qualified Country-by-Country Reporting to replace or simplify top-up tax calculations.
A new substance-based safe harbour targets tax incentives contingent on genuine economic activity. The amendment designates OECD global model rules and their official commentary as authoritative interpretive guidance for implementation. It also establishes successor liability mechanisms to clarify which entity assumes tax obligations when a taxpayer dissolves without a legal heir.
Societal, economic, and budgetary impacts
The explanatory report identifies mixed fiscal consequences from the draft amendment. The public administration budget faces negative impacts, while the business environment and digitalisation of society stand to gain positive effects. The amendment produces no consequences for public expenditure limits, social welfare, environmental protection, citizen-facing public services, or matters related to marriage, parenting, and family structure.
Interdepartmental comments and timeline to effectiveness
The draft amendment underwent an interdepartmental review spanning 25 June to 15 July 2026.
Seventeen comments were submitted during this period, with the Republic Union of Employers (RÚZ SR) and Klub 500 each raising fundamental objections. All disputes arising from these comments were resolved by 28 July 2026.
The law takes effect on 30 December 2026 for point 8 specifically, with all other provisions becoming effective on 31 December 2026.
