News in the field of taxation and accounting 6/2025

Čo v článku nájdete:

• Recent interpretations of the application of the Financial Transaction Tax Act
• Time limits in respect of the first tax periods (April 2025 June 2025)
• Interest on cashpooling
• C0010-C0020/R0300
• Travel expenses reimbursed
• Payment of a financial transaction tax
• Reduction of the ECB base interest rate with effect from 11 June 2025
• Current VAT information
• Limiting the deduction of input VAT for the acquisition of motor vehicles and related expenditure
• Judgment of the EU Court of Justice No C-262/24 Þ Pegazus Busz
• Introduction of self-taxation upon importation of goods from 1.7. 2025
• Questions and answers on the production of a simplified invoice up to the value of EUR 400 and on the deduction of VAT by the VAT payer from 1.1. 2025
• Information on amendments to Act No. 595/2003 Coll. on Income Tax, as amended

Recent interpretations of the application of the Financial Transaction Tax Act

The financial report of the Slovak Republic on its web portal regularly regulates and shares the latest interpretations on the application of the Financial Transaction Tax Act (hereinafter referred to as the “FTT Act’). Below we summarize the most important of them:

Time limits in respect of the first tax periods (April 2025 June 2025)

Member States shall determine how such reference is to be made. expires on 31.7. 2025. However, that time limit should apply only to those taxpayers and, at the same time, taxpayers (other than banks) who are taxable under Article 3 (3). Point 3 (3) of the FTT Act (i.e. the use of a foreign bank account) and in conjunction with Article 3 (3) (4) of the FTT Act (i.e. costs charged). The concession thus does not concern those taxpayers who have become taxable persons solely on account of the costs charged.

Interest on cashpooling

According to § 4 §. 2 letter (t) the FTT Act is not subject to a financial transaction which is a payment transaction with a single provider, related to automated offsetting of the balance of taxpayers’ accounts which are members of the consolidated whole for which consolidated financial statements are drawn up. Other financial transactions, such as payments to third parties (suppliers), clearing, offsetting of liabilities and claims representing cashpooling costs charged are subject to tax. Same interest paid on negative positions in cashpooling is also subject to tax.

C0010-C0020/R0300

According to the current interpretation of the Financial Report, payment of the motor repair invoice by the insurance undertaking in the event of liquidation of the insurance event is subject to a financial transaction tax, but Not considered cost accounting. The notification of a financial transaction tax is normally made by its payment service provider (i.e. bank) for the insurance undertaking. If a part of the car service invoice is paid directly by the company as an insured person, the bank of the insured is normally again in the position of taxable person.

Travel expenses reimbursed

In the case of secondment of a staff member to work, when the employer reimburses the staff member’s travel expenses (e.g. reimbursement of proven expenditure on accommodation, food, private car use during work and other expenses) It is not intended to be the costs charged from the perspective of the FTT Act. If the employer provides the employee with an advance or pays the employee a bill of business travel from the transaction account (e.g. when paying the salary), the tax payer is, in general, the employer’s bank. In the case of cash settlement, the transaction is not subject to a financial transaction tax.

If, however, the employee were to pay the document issued to the company from his own resources and would require compensation from the company, according to the current interpretation of the FTT law, it will be the company (employer)’s costs that should also take into account the identified transaction, i.e. the way the transaction was paid. If the transaction were paid by a cash employee or a payment card, the transaction would not be subject to a financial transaction tax. In any event, in the event of a business trip settlement and reimbursement of costs to an employee from a company’s transaction account, a company with major administrative difficulties could be relieved from a financial transaction tax where the bank would not have knowledge of this transaction, which should not be subject to tax.

Payment of a financial transaction tax

Financial transaction tax applies to the account number: 501403-OÚD (Personal Account of the taxpayer) /8180 in the form of IBAN. A variable 1700MMYYYY symbol shall be used for payment where MM (01 ♦ 12) indicates the calendar month for which the FTT is valid and the YYYY indicates the calendar year concerned. Payment of the tax on financial transactions for the tax period June 2025, the taxpayer designates the variable symbol 1700062025. Preliminary information to be prepared Another amendment to the FTT Act (except for the one we informed you about last month), including a change in the interpretation of the costs charged in relation to different practical situations, which should differ from the original interpretations by the Gesturers of the Act from the Ministry of Finance of the Slovak Republic. We are currently monitoring changes to the FTT Act and its current interpretation for you and will keep you informed.

All information about the financial transaction tax is regularly published on the website Financial report of Slovakia.

Reduction of the ECB base interest rate with effect from 11 June 2025

The ECB reduced the basic interest rate (interest rate on the main refinancing operations) with effect
From 11 June 2025 of the original 2.40% p.a. at 2,15% p.a.

Under the Law on the Administration of Taxes, the tax administrator applies fines for administrative fines of a monetary nature and interest on late payment rates linked to the ECB base interest rate (ECB ZUS).

Overview of fines and interest rates applied by the tax administrator Under § 155 and § 156 of the Tax Code (Law No 563/2009 Coll. on Tax Administration):

Source: Own processing

Source: Custom Processing  

Current VAT information

Limiting the deduction of input VAT for the acquisition of motor vehicles and related expenditure

With regard to limiting the deduction of input VAT in the case of the acquisition of motor vehicles and related expenditure in connection with their use, which we informed you about in previous news, we state that the planned amendment to the VAT Act, which was to transpose that restriction into the VAT Act with the intended effect from 1 July 2025, not yet published by the Ministry of Finance of the Slovak Republic. We will inform you about further developments.

Judgment of the EU Court of Justice No C-262/24 Þ Pegazus Busz

Pegazus provided bus services by applying a deduction of input VAT on invoices from subcontractors who did not transfer it on exit. Some subcontractors employed the same staff as Pegasus, who received orders from the same person all the time, used identical means of transport, had the same address and their VAT returns were submitted by the same person for a certain period of time.

Finally, the sub-contractors of Pegazus paid exit VAT. However, the tax authority questioned the deduction of input VAT in Pegazus Busz by the indication of tax fraud.. However, Pegazus did not notify the subcontractor concerned and, for the purposes of the VAT deduction, required controls by subcontractors, which it was not obliged to carry out. Similarly, the tax office did not examine the contradictions in employees’ claims, nor did the fact that a person managing employees in one company was also a responsible contact person within the meaning of subcontracting contracts. The Court of Justice of the EU has ruled that, in the sense of the right to a fair trial enshrined in Article 47 of the Charter of Fundamental Rights of the European Union, the taxable person is to be informed of the evidence relied on by the tax office in the statement that the taxable person is involved in tax fraud and is to be able to conflict with the relevant legal proceedings.

In accordance with the principle of primacy of EU law and Article 267 of the Treaty on the Functioning of the European Union, a national court is required not to apply the procedures resulting from national law if it considers that, in particular in the light of the judgments of the Court of Justice of the EU, it considers that it is contrary to EU law, without first having to refer the case to the EU Court of Justice. In June 2025, several information was also published on the website of the Slovak Financial Administration, some of which are briefly summarised below:

Introduction of self-taxation upon importation of goods from 1.7. 2025

In connection with the introduction of the VAT self-taxation mechanism for imports of goods from third countries from 1.7. 2025, the Financial Directorate of the Slovak Republic issued a press release informing about the details of this new mechanism. Until 30.6. 2025, the VAT administrator was the customs office which imposed the tax and established its maturity under the customs legislation ” unless otherwise provided by law. In well defined cases, when imported from third countries, the tax office will be after the new administrator. This will be a so-called self-taxation, and the importer himself will tax and tax it. This procedure shall apply to the importation of goods from third countries where the tax liability is due under the provision of Paragraph 21 (1) (a). (a) or (b) of the VAT Code:

• the release for free circulation, including end-use; or
• the placing of goods under the temporary admission procedure with partial relief from import duties,

and the payer on whose behalf the customs declaration (importer) is lodged shall, at the time when the charge becomes chargeable:

• registered office, place of business or establishment Domesticand, if he does not have such a place, resides in domestic,
• the assigned tax identification number under § 4; or Section 4b of the VAT Act, and
• an effective authorisation granting the status of authorised economic operator under customs legislation (any type of effective AEO authorisation is accepted).

The application of self-taxation to imports of goods from third countries shall be effected automatically when a customs declaration is lodged with the application for placing the goods under a customs procedure if the importer fulfils the above conditions. There is no need to apply for it. In the case of goods for which VAT is thus due, the importer is obliged to calculate the tax on imports of goods from third countries himself and to enter it in the tax return for the tax period during which the tax becomes chargeable.

Questions and answers on the production of a simplified invoice up to the value of EUR 400 and on the deduction of VAT by the VAT payer from 1.1. 2025

The information is intended primarily for VAT payers who, when selling goods or services, are obliged to produce a cashier’s document from the e-KASA Treasury client, but also for their customers, VAT payers who, on the basis of these documents, apply a deduction of the tax or cannot apply the deduction of VAT in the cases under consideration. You can find complete information with practical examples This document..

Information on amendments to Act No. 595/2003 Coll. on Income Tax, as amended

During June, the following information on the amendments to the Income Tax Act was published on the website of the Slovak Financial Administration:

• No 19/ADPAU/2025/I, which contains information on the amendment of the Income Tax Act following Law 104/2025 Act No 440/2015 Coll. on Sport. The changes relate exclusively to income tax for a natural person, which refines the income of sportsmen and sports professionals pursuant to Paragraph 6 (2) (a). (e) the Income Tax Act as well as other income pursuant to Paragraph 8 (1) (a). p) the Income Tax Act for sportsmen and sports professionals under the sponsorship contract;
• No 20/ZPAU/225/I Following Law 141/2025 Coll. amending Act No. 376/2022 Coll. on Professional Surrogate Parents. With effect from 1 January 2026, income exempt from income tax as defined in Article 9 (2) (a) of Regulation (EU) No 1307/2013 shall be included. (b) the Income Tax Act complements the financial contribution granted to a professional substitute parent to modify an apartment or family house pursuant to a special regulation;
• No 21/ADPAU/2025/I to the amendment of Law No 152/2025 Coll. the changes concern the introduction of a new type of other property in § 22 (6) (a). (f) and (g) the Income Tax Act, in terms of technical evaluation and corrections of at least 10% of the entry price of buildings used for the provision of accommodation services under the accommodation contract and for the purpose of carrying out sport. A depreciation period of 6 years is provided for this new type of other asset. The other assets in question are added in Annex 1 to this Act to Depreciation Group 2 as items 2-40 and 2-41. This means that the sum of the technical evaluation and corrections will be depreciated separately from the building on which the technical evaluation and corrections were made for a specified depreciation period of 6 years. In addition, depreciation periods are reduced for buildings where accommodation services are provided under the accommodation contract and associated services, and for buildings intended for sport and sport construction used for the purpose of carrying out sport.
• No 22/ADPAU/225By which The Financial Directorate of the Slovak Republic informs that with effect from 1 July 2025 the wording of § 9 (2) (a) is modified. (e) the Law on Income Tax, in accordance with which they are exempt from the tax on transactions defined therein, if they are provided in connection with the inclusion in the operational advances, standby advances and defence advances pursuant to Act No 150/2025 Coll. on certain measures to increase the resilience of the Slovak Republic in the field of defence and security and defence obligations.

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