Slovakia: Overview of top-up tax obligations for large groups under Pillar Two
Summary of filing requirements and deadlines for Slovak entities under Pillar Two rules
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march 26, 2026
The top-up tax applies to Slovak companies and permanent establishments (PEs) belonging to groups with a consolidated turnover of at least €750 million in at least two of the last four years. Every entity to which Pillar Two applies must submit:
- A GloBe information return (GIR) or a notification stating which entity within the group has filed the GIR on behalf of the group
- A tax return for the adjustment tax
These obligations apply even if no top-up tax is due, and each Slovak entity is required to file a tax return separately.
The effective tax rate is calculated per country, and the adjustment tax is then allocated among the individual companies in that country according to an allocation formula.
The deadlines depend on the accounting period:
- For the 2024 calendar year, the deadline for the GIR and the tax return is June 30, 2026.
- For a financial year, the deadline for the first tax period beginning no earlier than December 31, 2023, is 18 months from the end of that period.
- For subsequent tax periods, the deadline will be 15 months after the end of the period (e.g., for the calendar year 2025, by March 31, 2027).
Read a March 2026 report prepared by the KPMG member firm in Slovakia