Slovakia: Legislation amending Pillar Two rules approved by Parliament

Generally effective from December 31, 2025

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October 31, 2025

The National Council on October 21, 2025, approved legislation amending the Pillar Two rules to implement the EU DAC9 directive—providing for administrative cooperation and the exchange of information between EU member states—and align with OECD/G20 administrative guidelines.

The amendments specifically relate to:

  • New definition of reference entity
  • New rules for tax credits
  • Adjustment of monitoring deferred tax liabilities
  • Automatic exchange of information between states

Most of the changes become December 31, 2025, with some parts of the law becoming effective on January 1, 2026, or January 1, 2028.

Read an October 2025 report prepared by the KPMG member firm in Slovakia

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