A list of the most common “frequently asked questions”
A new financial transaction tax will be introduced in Slovakia on April 1, 2025. Read TaxNewsFlash. The new measures have raised a number of questions, especially from foreign companies that need to prepare for the new obligations.
The KPMG member firm in Slovakia prepared the following list of the most common “frequently asked questions” (FAQs):
Q. When does a foreign company pay financial transaction tax?
A. A foreign company pays tax on financial transactions if it has a payment account with a local payment service provider or carries on business in the country. In that case, its financial transactions carried out on the account abroad and related to the activity carried out in Slovakia are subject to tax.
Q. How should we understand the expression "activity in Slovakia"?
A. The Ministry of Finance has taken inspiration from the definition of a permanent establishment in Section 16 (2) of the Income Tax Act and added digital platform, online marketplace and insurance risks in interpreting this term. Thus, if a foreign entity has a warehouse in Slovakia, it carries on business in Slovakia. It is important to note that even if a permanent establishment does not arise (usually because of the exceptions in Article 5 of the double taxation treaty), the foreign company will still be liable to pay financial transaction tax.
Q. What is a recharge of costs?
A. Recharges of costs most often occur when a Slovak company enters into a contract with a third party (usually foreign) and asks it to remit funds or make payments to other entities (usually suppliers of the Slovak company) on its behalf. Such a payment is treated as a recharged expense and will be taxable at a rate 0.4 % of the tax base, with a maximum tax of €40 if the taxpayer can identify the individual payments made by the third party. If he cannot identify them, tax is payable on the entire amount of the expense, without applying the maximum amount of tax per transaction. In this case, the tax levied by the bank on the payment to the third party may be deducted from the tax on the costs recharged.
Read the March 2025 report