On 17 June 2026, the Government of the Slovak Republic adopted Resolution No. 251/2026, approving the conclusion of a Double Taxation Agreement (DTA) on income taxes and the prevention of tax evasion and avoidance with the Democratic Socialist Republic of Sri Lanka. The resolution authorizes the signing and ratification process for the agreement.1
WHY THIS MATTERS
This proposed Double Taxation Agreement is relevant for organizations and individuals with cross-border income between Slovakia and Sri Lanka, including globally mobile employees, HR leaders, and payroll managers. Once ratified and in force, the agreement may provide relief from double taxation, clarify tax residency, and establish procedures for information exchange and dispute resolution. For globally mobile employees and their employers, this may improve tax certainty and affect payroll withholding, reporting, and double-tax relief positions.
For mobile employees, the agreement may prevent income from being taxed in both jurisdictions and provide frameworks for credit or exemption mechanisms. Employers may also benefit from simplified payroll administration and clearer tax obligations for assignees.
Key Highlights
- Approval and signature authorization: The government consents to conclude the DTA and will not require post-signature resubmission.
- Designation of signatories: The Prime Minister, Minister of Finance, Deputy Prime Minister, Minister of Economy, Minister of Foreign and European Affairs, and other specified officials are authorized to sign the agreement subject to ratification.
- Parliamentary and presidential procedures: The National Council (parliament) is requested to approve the treaty and recognize it as an international agreement with legal precedence over domestic law, pursuant to Article 7(5) of the Slovak Constitution.
- Implementation measures: Upon signature, the agreement will be submitted to parliament for approval and subsequent ratification by the President. The Minister of Finance is tasked with supporting the approval process and coordinating publication in the Collection of Laws.
KPMG INSIGHTS
As the agreement has only been approved by the government at this stage, the substantive treaty benefits are not yet available. Employers and affected stakeholders might wish to consider:
- Review populations with employment income, board remuneration, or other cross-border income connected to Slovakia and Sri Lanka.
- Assess whether current payroll withholding, shadow payroll, and reporting positions may need to be revisited once the treaty is ratified and enters into force.
- Identify mobile employees whose tax residency, double-tax relief, or treaty-claim positions could be affected by the final treaty provisions.
- Monitor the parliamentary, presidential, and publication steps so any future compliance or communication changes may be implemented on a timely basis.
If assignees and/or their programme managers have any questions or concerns about the scope of the update, its application and potential impacts, and appropriate next steps, they should consult with their qualified professional or a member of the GMS team with KPMG in Slovakia (see the Contacts section).
ENDNOTE:
1 Úrad vlády Slovenskej republiky (in Slovak), “Detail uznesenia,” published on 17 June 2026.
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Disclaimer
The information contained in this newsletter was submitted by the KPMG International member firm in Slovakia.
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