The Slovak Republic government approved Government Resolution No. 320/2026 on 19 August 2026 to amend Act No. 507/2023 implementing the EU Minimum Taxation Directive, incorporating OECD/G20 Inclusive Framework safe harbours for qualified Country-by-Country Reporting and tax incentives demonstrating economic substance.
The Slovak Republic government has approved a draft bill amending Act No. 507/2023 Coll., which implements the EU Minimum Taxation Directive. The draft bill was approved by Government Resolution No. 320/2026 on 19 August 2026.
The bill introduces further adjustments arising from the OECD/G20 Inclusive Framework’s Side-by-Side Package, adopted on 5 January 2026, including related administrative guidance to the global minimum tax rules.
On 12 January 2026, the European Commission published a Communication recognising the application of this agreement under EU Directive (EU) 2022/2523. The amendment integrates this guidance to prevent legislative drift.
The OECD announced on 5 January 2026 that the 147 members of the OECD/G20 Inclusive Framework on BEPS had reached agreement on key elements of a side-by-side arrangement, including two safe harbours for multinational enterprise groups headquartered in jurisdictions with eligible tax regimes.
Key changes
The amendment extends the existing safe harbour exemption for entities relying on qualified Country-by-Country Reporting (CbCR) and establishes a new exemption for tax incentives demonstrating economic substance. It clarifies which entity assumes outstanding tax obligations when a taxpayer dissolves without a legal successor. OECD global model rules and their accompanying documents are designated as official interpretative material for implementing the law.
Earlier, the Slovak Ministry of Finance launched a consultation on 25 June 2026 on Draft Law No. LP/2026/369, which proposes amendments to Act No. 507/2023 Coll. implementing the EU Minimum Taxation Directive. The amendments aim to incorporate the OECD/G20 Inclusive Framework’s Side-by-Side Package adjustments to the global minimum tax rules.
