
Bratislava – On Friday, the President of the Slovak Republic, Peter Pellegrini, enacted an amendment to the equalization tax law. This legal standard, put forth by the Ministry of Finance (MF) of Slovakia, received final approval from the National Council (NC) on November 28, as reported by TASR.
Last year, the equalization tax law integrated a key EU directive into Slovak legislation, aligning with the global model rules set forth by the Inclusive Framework of the OECD/G20. The objective is to establish a minimum tax rate of 15% on income for entrepreneurs in Slovakia who belong to a multinational or substantial national corporate group.
To further clarify and enhance international regulations, administrative guidelines were introduced in 2023. While these guidelines do not form part of the directive, EU member states have pledged to implement them.
According to the Ministry of Finance, “The purpose of the bill is to incorporate the guidelines that have been approved to date, ensuring that all conclusions drawn from them are effectively implemented. In certain instances, it is essential for the rule to be explicitly defined in law to provide a greater level of legal certainty.”
The amendment features refinements and additions to the calculation of eligible income and losses of the primary entity, as well as adjustments to the calculation of included taxes. It also clarifies established definitions, introduces rules for calculating excluded income based on economic substance, and presents simplified calculations for minor entities.
The new legislation will come into effect on December 31, 2024. (December 13)













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