News in the field of taxation and accounting 7/2025

Čo v článku nájdete:

• E-invoicing since 2027 and 2030 respectively – legislative process
• Latest information on the Financial Transaction Tax Act
• Foreign person with an establishment in the Slovak Republic
• Indirect amendment to the FTT Act
• Current VAT information
• New VAT return form valid from 1.7. 2025
• Information No 5/VAT/2025/I on Article IV of Law No 181/2025
• Judgment of the Court of Justice of the EU No C-276/24
• Update on the amendments to Act No. 595/2003 Coll. on Income Tax, as amended
• Other selected changes

E-invoicing since 2027 and 2030 respectively – legislative process

The Ministry of Finance of the Slovak Republic submitted a draft law amending the VAT Act with the primary objective of transposition of Council Directive (EU) 2025 of 11 March 2025 amending the Directive on the common system of VAT. The draft law aims to introduce mandatory electronic invoicing as well as mandatory digital communication of real-time supplies of goods or services to taxable persons who are taxable persons of value added tax. This change in invoicing is intended to simplify and clarify invoicing while contributing to the fight against tax evasion. The preliminary timetable / effectiveness of the law implementing electronic invoicing and the related obligations declared by the Ministry of Finance of the Slovak Republic are as follows:

• With effect from 1 January 2027, the obligation to issue and receive electronic invoices in a specified format for taxpayers established in the domestic context of domestic supplies of goods and services is laid down.
• With effect from 1 July 2030, it is envisaged to introduce an obligation for all taxable persons to invoice and communicate electronically, including for cross-border supplies of goods or services.
• In addition, with effect from 1 July 2030, for domestic taxable transactions, the same time limit for the production of electronic invoices and the same method of reporting data as for cross-border taxable transactions is laid down and the obligation to submit a control statement and a summary statement is completely abolished.

In this context, the Financial Directorate of the Slovak Republic informed on its website even earlier that it started to work on creating an environment for electronic invoicing. She chose to do it. Peppol networkset up by the European Commission in 2011 and is still coordinating it. The concept of this solution has already been presented to business partners. The system should work by sending an invoice to the customer via Peppol, with certified Peppol providers in charge of delivery, who will also send selected invoice and financial management data. Invoices will no longer be sent by e-mail (e.g. in pdf format), but in a standard XML format that meets the European standard, using a secure communication protocol. Entrepreneurs will be able to use a simple user environment or use an individually automated solution integrated into their accounting systems (API). We will monitor the development of the draft law in the legislative approval process for you and keep you informed about the news.

Latest information on the Financial Transaction Tax Act

With regard to the Financial Transaction Tax Act (hereinafter referred to as the FTT Act) below, we summarise current changes / interpretations of the Financial Report:

Foreign person with an establishment in the Slovak Republic

According to the current interpretation of the Financial Report of the Slovak Republic, the costs charged by the foreign guarantor to the domestic branch (so-called “in-house”) for the purposes of the FTT Act are no longer considered as costs charged. The organisation does not therefore become a taxable person pursuant to Paragraph 3 (3) (4) of the FTT Act, even in the situation where the founder pays a liability abroad that is settled (in full or in part) in the internal costs of the company in question.

It is therefore a new approach to the declaration of these debit financial transactions compared to the situation which was presented from the very beginning by the law gestors from the Ministry of Finance of the Slovak Republic. Despite the fact that the financial report of the Slovak Republic no longer discusses how the above-mentioned debit transactions, related to the conduct of business in Slovakia, are to be reported for financial transaction tax purposes, according to unofficial information, the branch becomes a tax payer under the title of § 3 (3) of the FTT Act (i.e. the use of a foreign bank account).

Indirect amendment to the FTT Act

The amendment to the Act on Education and Education, the so-called School Act (Law No. 176/2025 Coll.) also introduced an indirect amendment to the FTT Act. The amendment concerns the addition of a new point in the exemption from the scope of taxation in Paragraph 4 (2) of the FTT Act, under which the tax on financial transactions is subject to is not a payment operation by a taxpayer, which is a State-recognised Church or a religious society, from a special account in favour of a school account or school establishment within its jurisdiction of establishment, in the case of funds from a State budget under a special regulation. It shall take effect from the date of its notification, i.e. 30 June 2025.

Current VAT information

New VAT return form valid from 1.7. 2025

We are again paying attention to the new VAT return form applicable from 1 July 2025. The new VAT return form will be used for the first time when filing a tax return for the July 2025 tax period or for the 3rd calendar quarter of 2025 tax period. The Ministry of Finance of the Slovak Republic also issued an instruction to complete the tax return on value added tax determined by the notification of the Ministry of Finance no. MF/007833/2025-731. The electronic VAT return form as well as the instructions for its completion are available on the Slovak Financial Administration portal in the Form section.

Information No 5/VAT/2025/I on Article IV of Law No 181/2025

The information summarises the specific changes to the VAT Act following Law No 181/2025. The changes relate to the introduction of a self-taxation institute for the importation of goods and concern the obligation for the taxable person to make a correction of the tax base and the tax also in cases where, when the goods are imported, the tax is not levied by the customs authority and the tax base on importation is changed due to the reduction or increase of the related costs referred to in Article 24 (2) or (4) of the VAT Act. In this context, the method of declaring the correction of the tax base and the tax in the tax return, as well as the obligation or right to correct the deducted tax in the event of self-taxation when goods are imported into domestic territory, are also regulated. The list of goods to which a reduced tax rate of 5% of the tax base applies is also extended by specific goods, as well as by the list of services to which a reduced tax rate of 5% of the tax base applies.

Judgment of the Court of Justice of the EU No C-276/24

KONREO, v.o.s. (hereinafter referred to as “KONREO”) is the insolvency administrator of FAU s.r.o., established under Czech law for which bankruptcy was declared. From May to October 2013, FAU purchased fuel from Verami, another company established under Czech law. After carrying out tax controls, the tax administration found that the business chain, which includes Verami and FAU, was burdened with tax fraud. The tax administration issued additional payment notices to Verami to cover the VAT owed by the company, denying it the right to deduct VAT on fuel purchases, which it subsequently supplied to FAU. Verami did not pay this VAT. The tax administration also cleared the VAT of FAU by denying it the right to deduct VAT on fuel invoices on account of VAT fraud in the business chain involving the transaction carried out by that company. The financial directorate of appeal takes the view that taxable persons who deliberately participated in tax fraud cannot rely on the principle of fiscal neutrality and that there is nothing to prevent the taxable person from simultaneously denying the right to deduct tax on supplies affected by tax fraud and, at the same time, the taxable person from having to pay the VAT due by his supplier on the basis of legal liability. The Court of Justice of the EU held that Article 205 of the VAT Directive, read in conjunction with the principle of proportionality, does not preclude national practice which does not prevent a taxable person from receiving supplies of goods for consideration, imposes a joint and several liability to pay the VAT owed by the supplier of those goods, even though the recipient of that supply was denied the right to deduct VAT due or paid on entry on the ground that he knew or should have known that he was involved in VAT fraud.

Methodological guidance No MF/011480/2025-731 on applying a reduced rate of value added tax to newspapers, magazines and periodicals from 1.7. 2025

With effect from 1 January 2025, a reduced VAT rate of 5% was introduced, inter alia, on newspapers, magazines and periodicals, whether or not illustrated or containing advertising material, originating at least four times a week except for newspapers, journals and periodicals, whether or not illustrated or containing advertising material in which advertising and advertising individually or together represents more than 50% of the total content of the product and, except for newspapers, journals and periodicals, whether or not illustrated or containing advertising material in which the erotic content represents more than 10% of the total content of the product individually or together. With effect from 1 July 2025, the indirect amendment to the VAT Act deleted from the description of the goods mentioned above (i.e. under the SCS code ♦ex 4902 10 00 This deletion is intended to extend the list of goods, such as newspapers, magazines and periodicals, which meet the condition of a limited scope of advertising and erotic content to which a reduced tax rate applies, irrespective of their frequency of return. However, since the relevant SCS code has not been adjusted, the Ministry of Finance of the Slovak Republic clearly states in the Guidelines that a reduced tax rate should be applied to newspapers, magazines and periodicals for all printing, fulfilling the condition of the maximum scope of advertising and erotic content, in order to remove any doubt and possible difference in the application of the reduced tax rate to those goods, regardless of the frequency of its curing, i.e. even less often than four times a week.

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

During July the following information related to the Income Tax Act was published on the website of the Slovak Financial Report:

• No 24/ZPAU/2025/I, which contains information on the amendment of the Income Tax Act following Act No 153/2025 Coll. With effect from 1 January 2026, the amendment of the Income Tax Act introduces a new exemption of income from dependent activity and a new tax advantage in the form of deduction of expenditure (costs) on the promotion of sport. We informed about this amendment in more detail in May news. The financial report in the information summarises these adjustments. For full information Here..
• No 25/ADPAU/2025/I following Law No 200/2025 Coll. amending Act No. 359/2015 Coll. on the automatic exchange of financial account information for tax administration purposes. The amendment in question V with effect from 1 January 2026 in the Income Tax Act
• extends the reporting obligation of the taxable person pursuant to Paragraph 43 (11) of the Income Tax Act by withholding tax broken down by taxpayer, not only if it is a taxpayer from a non-cooperative jurisdiction, but in relation to all taxpayers with a limited tax liability under Paragraph 2 (a). e) Income Tax Act, at the same time
• supplement the provisions to the parent’s share of tax paid under Section 50aa of the Income Tax Act. The income accruing to the parent from the share of tax paid to the parent shall be added to the income which is not subject to tax pursuant to Article 3 (2) (a). (e) the Income Tax Act. In addition, the procedural requirements for the share of the tax paid to the parent, such as verification of the fulfilment of the conditions, the transfer of the parent’s share, the cessation of the entitlement to demonstrate the proportion of the tax paid to the parent, or the establishment of a register of relations with the parent and the child.
• No 27/DZPAU/2025/I to the Action of the Ministry of Finance of the Slovak Republic dated 2 July 2025 No MF/008447/2025-74 amending the measure of the Ministry of Finance of 14 June 2023 No MF/006455/2023-74 on the report on income tax information (hereinafter referred to as the “new measure’) With effect from 10 July 2025, the original measure is amended following the amendment of Act No 431/2002 Coll. on Accounting as amended. The amendment removes from the obligation to keep the report in the Register of Financial Statements the entities subject to the obligation to keep the report on income tax information under Paragraph 21a of the Accounting Act. They are required, pursuant to Article 23a (11) of the Accounting Act, to deposit a report with information on income tax in electronic format in accordance with the model laid down by Commission Implementing Regulation (EU) 2024/2952 of 29 November 2024 (OJ L 2024/2952, 2.12.2024). This is the ultimate parent entity and a separate entity if they meet the conditions in Paragraph 21a (1) of the Accounting Act.

Other selected changes

• Law No 200/2025 Coll. amending Act No. 359/2015 Coll. on the automatic exchange of financial account information for tax administration purposes. The amendment effective as of 1 January 2026 primarily introduces the automatic exchange of information on cryptoactives in accordance with Council Directive 2023/2226/EU, the so-called DAC Directive8.

Article II amends Law 78/1992 Coll. on Tax Advisors and SKDP, in particular, the scope of the duty of secrecy in the performance of the tax advisor’s activities is governed by the following amendments to the DAC Directive8, judgment of the Court of Justice of the European Union in Case C-623/22 Belgian Association of Tax Lawyers and Others v Premier ministre v Eerste Minister and OECD Recommendation from peer review Slovak Republic for the purpose of information exchange on request in accordance with the international standard. If you are not aware of your tax or accounting questions, do not hesitate to contact us contact.

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