The government of the Slovak Republic has approved the draft law amending the Income Tax Act and the Act on Tax Administration. The amendments include following changes:

  • implementation of rules on restriction of interest deduction in accordance with the EU Anti-tax Avoidance Directive (ATAD);
  • amending definitions of foreign related party, significant controlled transactions, and controlled transactions;
  • clarifications and additions to the transfer pricing rules;
  • clarifications of  permanent establishment; and
  • new penalty provisions.

In order to become effective, the draft law required to be approved by the parliament and signed by the president. Generally, the amendments are to enter into force on 1 January 2023 and for the interest limitation amendments apply from 1 January 2024.