News in the field of taxation and accounting 10/225

Čo v článku nájdete:

• New forms of income tax returns
• Change in the amount of food from 1 December 2025
• New Guideline MF SR on Transfer Documentation
• Amendment to the Equalisation Tax Act
• Government Bill on Sales Registration
• Judgment of the European Court of Justice in Case C-234/24 Brose Prievidza
• In conclusion

New forms of income tax returns

On October 13, 2025, the Ministry of Finance of the Slovak Republic published in the Financial Rapporteur notices on the issue of model forms of tax returns for natural and legal persons, together with lessons and models of tax return certificates. The new forms will be used when filing tax returns with taxpayers, the last day of the period for filing the tax return shall expire not earlier than 31 December 2025.

The changes in the corporate income tax form (‘DPPO’) can be summarised in two parts:

Follow-up to approved amendments to the Income Tax Act (hereinafter referred to as “AZDP’) namely:

• a reduction in the tax base for deduction of expenditure (costs) in support of sport under Section 30ca of the ZDP,
• changes in corporate income tax rates and limits for setting the tax rate – applied from 2025;
• tax on the special tax base pursuant to § 51ea ZDP on the proceeds of government bonds and Treasury bills.

Change of table I – Dependent person transactions according to § 2 (a) (n) the ZDP (by 100 or by 301), the most significant adjustments being:

• the title of the reference table also in 301 (tax base or tax loss) for taxpayers who do not show a profit or loss (e.g. some permanent establishments);
• the extent of the information reported broken down into (i) the serial number of the transaction, (ii) the code of the type of transaction from the code book that forms part of the instruction to the DPPO, (iii) the impact on the profit or loss outcome or tax base, (iv) the name of the dependent person, (v) the country code of the tax resident dependent person (counterpart of controlled transaction).

The guidance to DPPO shows that depending on the number of controlled transactions or groups of controlled transactions, the taxpayer will add rows in the table if necessary (maximum number of rows is 99). Where the maximum number of lines is not sufficient to indicate all significant controlled transactions, controlled transactions with the lowest value shall be omitted from Table I. Significant controlled transactions not included in the tax return due to insufficient number of lines will be reported in the shortened transfer pricing documentation.

Taxpayers who complete Table I do not need to lead to reduced transfer pricing documentation with the exception of the above condition, i.e. if significant controlled transactions are not included in the tax return due to insufficient number of lines.

Changes in the form of personal income tax (type A/B) are in particular:

• the addition of a section to show the share of income tax paid by both the individual and the taxpayer’s parents (the possibility of showing the share of tax paid to non-profit organisations has been maintained);
• calculation lines concerning e.g. tax bonus, tax loss application (type B),
• new Annexes 1c and 3 in the B-type tax return, i.e. deduction of expenditure on sport support and revenues from government bonds and Treasury bills, the original Annex 3 for social/health insurance purposes being moved to Annex 4.

Change in the amount of food from 1 December 2025

The Ministry of Labour, Social Affairs and Family of the Slovak Republic, by the Communication No. 280/2025 Coll. on the amount of food increased with effect from 1. 12. 2025 the amount of food provided for the work of employees:

1. EUR 9.30 for the time zone 5 to 12 hours;
2. EUR 13.80 for a time zone over 12 hours to 18 hours;
3. EUR 20,60 for a time zone over 18 hours.

This will also have a direct impact on staff eating with effect from 1 December 2025, i.e.:

1. the minimum value of the gastro-list will be EUR 6.98, with a minimum contribution of EUR 3.84;
2. the financial contribution for the diet shall be at least EUR 3,84 and a maximum of EUR 5,12.

At the same time, the employer can also use funds from the Social Fund to feed employees, beyond the amounts mentioned above.

New Guideline MF SR on Transfer Documentation

In October, the Ministry of Finance of the Slovak Republic issued a new Guideline No MF/012879/2025-724 on the determination of the content of transfer documentation (hereinafter referred to as “the Guideline’) replacing the current Guideline No MF/020061/2022-724. The new Guideline shall be used for the first time in the preparation of documentation for the tax period for which the last day of the period for filing the tax return expires not earlier than 31 December 2025.

The types of documentation within the meaning of the new Guidelines remain identical, i.e. complete, basic and abbreviated, with only minimal changes in the content requirements for each type of documentation. As mentioned above, the shortened documentation almost loses ground as a large part of the transactions will be re-listed in Table I of the income tax return. On the one hand, this change will entail a reduction in the administrative burden for a certain group of taxpayers, who will thus have their documentation obligation to submit a tax return, on the other hand, a new table I provide tax administrations with more detailed information on significant controlled transactions carried out and give tax administrations greater scope to analyse and detect potential irregularities. In addition to the above, the definition of a group of controlled transactions was further clarified. This is newly defined as several transactions audited, executed also with different counterparties, if it concerns:

• transactions of the same type and concluded on comparable terms,
• closely interconnected and interdependent, or
• comparable in terms of assets, functions and risks being used.

However, according to the OECD Transfer Pricing Directive, on which principles the Guideline is also based, the aggregation of individual controlled transactions into a group should not mask the economic substance and possible compensation for loss-making transactions with over-profits or the transfer of profits to other jurisdictions.

Amendment to the Equalisation Tax Act

The National Council of the Slovak Republic approved the amendment of Act No 507/2023 in October Z. from the Equalised Tax to ensure a minimum level of taxation for multinational groups of enterprises and large national groups (hereinafter referred to as “the DD Act’) as well as the Law No 442/2012 Coll. on International Assistance and Cooperation in Tax Administration (hereinafter referred to as “the Amendment on International Cooperation’). The law on DD has been in force in Slovakia since 2024. Within the framework of administrative obligations, a taxpayer falling within its scope is obliged to submit to the tax administrator, within 18 months of the end of the first tax period, a completed form of notification with information to determine the taxed tax and return. The first submissions relating to the tax year 2024 shall be made by 30 June 2026. However, in relation to the notification of the information to determine the equalised tax, the law relieves the taxpayer from filing it if the principal parent entity or another entity on behalf of the group (the designated reporting entity) makes the notification for the whole group. The taxpayer shall notify the tax administration of this fact by 30 June 2026. The amendment to the DD Act introduces a structured form for this notification obligation, which will be submitted via the electronic portal of the Financial Report.

In addition, the amendment to the Act on DD complement the rules for transparent entities, reverse hybrid entities and introduce clarifications and additions in relation to the modification of the deferred tax liability. The amendment to the Act on International Cooperation introduces a standard template for the communication with information to determine the adjusted tax, which will be published on the website of the Financial Directorate of the Slovak Republic. Under the DD Act, the condition for exempting the taxpayer from submitting a notification with information to determine the taxed tax is that this submission will take place in the State with which the Slovak Republic has an effective so-called qualified agreement of the competent authorities under which the State of filing sends the relevant part of the notification to the tax administrator in the Slovak Republic. The amendment to the Law on International Cooperation introduces the conditions for the exchange of such notifications between EU Member States. On 16 June 2025, the Slovak Republic acceded to the Multilateral Agreement of the competent authorities of the OECD in order to exchange notifications with third countries.

Government Bill on Sales Registration

In the second half of October a recast law on the use of cash registers was discussed in the National Council of the Slovak Republic in I. reading. The government draft law is up to date until 24 November 2025 on the Committees.

The revision of the Act on the use of cash registers follows, according to the explanatory memorandum, the clarification of the law after the end of the use of electronic cash registers and the subsequent introduction of online cash registers in relation to new trends in the register of sales, as well as the clarification and modification of certain selected provisions, taking into account knowledge of the practice. The new law is to apply to a seller who will be understood as a natural or legal person who is entitled to conduct a business or to engage in another self-employment activity and will receive sales for the sale of goods or the provision of a service. It is proposed to introduce a new type of treasury, the so-called “software online cash register’, whereby an entrepreneur (seller) may decide whether to use this type of treasury or to use the online cash register or virtual cash register. Furthermore, the draft law proposes to introduce a new obligation for entrepreneurs, namely to notify the treasury failure to the Finance Directorate via the eKasa Business Area. Other obligations, whether for businessmen, manufacturers, importers and cashier distributors, remain more or less the same. On the basis of the Action Plan to combat tax evasion, the following changes are also introduced compared to the current ERP:

• the introduction of an obligation for all entrepreneurs who will be obliged to register sales via eKasa (see comments below) to allow the buyer to make payments in cash by scanning the QR code through a banking application or another means of payment;
• the removal of the current Annex 1 of the ERP Act, which includes services which are subject to the obligation to register turnover in the e-Customs or via the e-Customs of e-Customs, the Government is hereby monitoring the equalisation of the status of all operators providing services and the removal of the benefits for those who do not need to use e-Casa under the current wording of the Act.

The exemption from the use of eKasy, and therefore the obligation to allow for non-cash payment, will apply, for example, to the sale of prices, public transport tickets, printing, goods and services by means of vending machines, mail order goods, goods and services by a natural person with a severe disability (except where a natural person who is not a GMP receives a sale for such a person) or goods and services in alpine establishments without connection to the networks concerned. The new Sales Register Act will only concern the register of sales at eKasa Treasury. Original Law No 289/2008 Z.z. on the use of electronic cash registers, as amended, is repealed by this draft law.

The proposed effectiveness of the new law is planned from 1 January 2026, while the obligation to allow cash payments to sellers is proposed through a transitional provision to 1 March 2026.

We will continue to monitor and keep you informed of legislative developments.

Judgment of the European Court of Justice in Case C-234/24 Brose Prievidza

Brose Prievidza, Slovak VAT payer, carries out activities consisting mainly in the production of window controls and door modules for motor vehicles. For the production of these products, it buys components from the Bulgarian company “Integrated Micro-Electronics Bulgaria”” EOOD (hereinafter referred to as “IME Bulgaria’). The German company Brose Fahrzeugteile SE & Co. KG (hereinafter referred to as “Brose Coburg”) which is part of the Brose group and has a VAT registration in Germany and Bulgaria has ordered a separate component manufacturing facility from IME Bulgaria. Although this facility became the property of Brose Coburg, it remained in IME Bulgaria, which used it exclusively for the production of the abovementioned components intended for Brose Prievidza. Brose Coburg later sold the same facility to Brose Prievidza. The sale invoice for this facility also contained the Bulgarian VAT paid. The contested facility remained in IME Bulgaria for the purpose of producing these components. The Bulgarian authorities rejected Brose Prievidza’s request for VAT refunds on the ground that the delivery of the contested equipment was ancillary to the supplies of components produced by IME Bulgaria and should therefore be subject to the same tax regime (i.e. exemption). The supply of equipment should not have been artificially separate from them, in terms of VAT. The ECJ decided that Article 4 (a) of the EC Treaty should be replaced by the following: (b) Council Directive 2008/9/EC laying down detailed rules for the refund of VAT, read in conjunction with Articles 138 (1) and 171 of the VAT Directive, is to be interpreted as meaning that precludes the refund of VAT on the supply of equipment to a taxable person established in a Member State other than the Member State of purchase of those goods if that establishment has not physically left the territory of the Member State of its supplier, unless, in the light of all the circumstances characterising the transactions in question, that supply should be considered to be part of a single economic transaction which is inseparable or incidental in relation to a principal performance consisting of the intra-Community supply of goods produced by that establishment and intended by that taxable person. In its statement, the Court also considered and deduced the following:

• the fact that several supplies of the same goods were made between the same companies is not sufficient to conclude that these supplies must be considered as a single transaction in themselves and independently of the delivery of the contested equipment. The conformity of the subjectmatter of those supplies does not automatically mean that they constitute objectively the only integral economic performance, the division of which would be artificial,
• the fact that there is a link between the transactions, since the equipment at issue is necessary for the production of components, does not mean that they must be regarded as a single transaction and therefore as inseparable transactions,
• the fact that the equipment is not intended for the production of one piece or one delivery of parts or for incorporation into components, but is intended for the serial production of those parts or components, may contribute to the demonstration that the supply of such equipment is not so closely linked to the specific delivery of parts that it must be regarded together with this specific supply of parts objectively as part of a single integral economic performance;
• it may be assumed that the equipment will be used throughout the entire production cycle of the goods produced using this equipment, which is the reason why it was provided to the manufacturer. The supply of such equipment therefore has its own purpose in relation to the various supplies of components, so that it cannot be regarded as ancillary to those supplies.

In conclusion

• The financial directorate of the Slovak Republic published information on the amounts needed to calculate the tax liability of the natural person for the year 2026, following the increase in the amount of the valid minimum life to one minor natural person on 1.7. 2025 at the amount of 284.13 Euro. Line.
• Notice of the Ministry of Finance of the Slovak Republic on the determination of patterns of forms in relation to dependent income from 10.10. 2025 contains new models of forms for the annual settlement of advance payments for tax on dependent income, declaration of tax billing and aggregation of income from dependent work and an overview of the deducted and deferred tax advances on dependent income. You can find the notification and specimen forms on this Line under contribution No 24.
• Information from the Financial Directorate of the Slovak Republic on the new model of the Financial Transaction Tax Communication, which will be used for the first time for the January 2026 tax period. You can find out about this Line.
• Information from the Financial Directorate of the Slovak Republic to the amendment of the Financial Transaction Tax Act (effective from 1 January 2026). We informed about the amendment of the FTT law in more detail in previous news. From additional information relevant to a better understanding of some provisions of the law, we choose:
  • the tax liability, following a legislative change relating to the establishments, arises for foreign persons in the notifications for January 2026 and will be subsequently filled in under the heading of the notification the identification data (trade name and registered office) of the foreign guarantor;
  • the taxable person is liable after 31 December 2025 to pay tax for tax periods preceding the entry into force of this Act for natural persons and businesses;
  • Article 3 (3) (a) (e) the FTT Act extends the definition of the payer, where, in addition to the previous definition of the payer as a taxpayer who has carried out a financial transaction in a non-transaction account, the taxpayer who has carried out a financial transaction which is not excluded from the subject matter of the tax is also included in the separate account in which the financial transactions that are not subject to tax are carried out pursuant to Article 4 (4). 2. This extension of the group of payers aims to discourage taxpayers from carrying out financial transactions which are not excluded from the subject-matter of the tax on a separate account intended for financial transactions which are not pursuant to Article 4 (4). 2 subject to tax.