Slovakia: Guidance on financial transaction tax
Guidance clarifies assessment of performing a taxpayer’s activity in Slovakia, taxation of recharged costs, and transactions that are not subject to tax in the case of cash pooling
The Ministry of Finance of the Slovak Republic issued guidance on the financial transaction tax that clarifies the assessment of performing a taxpayer’s activity in Slovakia, the taxation of recharged costs, and transactions that are not subject to tax in the case of cash pooling.
Performing activity in Slovakia
A taxpayer’s activity is considered to be performed in Slovakia if it is:
- Carried out wholly or partly through a permanent place or facility for carrying out activities located in Slovakia—considered permanent if used continuously or repeatedly for the majority of the monthly tax period. In the case of a construction site, place of construction projects, or assembly projects, the time test for permanence does not apply
- Carried out through a person who acts on behalf of the taxpayer and, continuously or repeatedly for the majority of the monthly tax period, negotiates or concludes contracts on their behalf based on authorization
- A platform or online marketplace is located in Slovakia
- An insurance risk related to this activity is located in Slovakia—i.e., real estate, its components, accessories, including items located therein (except goods in commercial transport), located in Slovakia, and vehicles registered in Slovakia
Recharged costs
The guidance clarifies what is considered recharged costs:
- A situation when the taxpayer enters into a contract or other similar legal relationship with a third party, the content of which includes the transfer of funds or payments by the third party to other entities on behalf of the taxpayer
- Cost allocation
Cash pooling
For the purposes of exemption from the tax base, it is not decisive where the provider maintaining the accounts of the members of the consolidated group is located, nor according to which rules the consolidated financial statements for the consolidated group are prepared. However, the requirement for a single bank remains.
Read a September 2025 report prepared by the KPMG member firm in Slovakia