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The equalization tax will be adjusted according to the new guideline
Bratislava, 19.08.2026
Completing the necessary adjustments resulting from the new guidance on the global model rules against the erosion of the tax base, as well as taking into account suggestions from application practice. These are the objectives of the draft amendment to the Act on the Additional Tax from the Ministry of Finance (MF) of the Slovak Republic, which was approved by the government on Wednesday. The Additional Tax Act transposed the relevant European directive into Slovak law several years ago. Its wording is based on the global model rules adopted by the Organization for Economic Cooperation and Development (OECD) and the G20 in 2021. Administrative guidelines are being adopted on an ongoing basis to clarify and supplement the application of these rules, most recently in early 2026. These guidelines also need to be taken into account in Slovak legislation. "The bill contains an extension of the transitional safe harbor - exceptions from the calculation of the catch-up tax based on qualified country-by-country reporting (CbCR) and a new safe harbor - an exception for tax incentives tied to economic substance. The bill also contains further clarifications resulting from application practice," the submitter explained in the explanatory memorandum. The bill also includes ensuring the continuity of tax obligations in the event of the taxpayer's demise without a legal successor, by determining the entity to which this obligation is transferred. The changes resulting from the amendment are to enter into force gradually on 30 and 31 December this year.odkaz na stránku
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