New rules for financial transaction tax
Act No. 272/2025 Coll., amending Act No. 279/2024 Coll. on Financial Transaction Tax, and on amendments to certain acts, as amended (hereinafter “FTT”), was published in the Collection of Laws.
Compared to the original draft, which we informed you about in previous editions, the following key changes were finally approved.
Exclusion of natural persons – entrepreneurs from FTT
Exclusion of Natural Persons – Entrepreneurs from the scope of FTT taxpayers and removal of their obligation to conduct business related financial transactions through a transaction account.
New definition of taxpayer and permanent establishment
Introduction of a new definition of a taxpayer with unlimited and limited tax liability and consequently defining the performance of activities of foreign persons in Slovak Republic through a permanent establishment.
The amended definition implies, among other things, that the registered branch of a foreign person will no longer be a separate taxpayer of the FTT, but instead the foreign legal entity (founder) will be considered a taxpayer to the extent of financial transactions carried out in connection with the activities of its permanent establishment in the Slovak Republic.
Definition of so-called ‘charged costs’
Introduction of the definition of so-called ‘charged costs’ directly into the Act. The charged cost shall be understood as the amount of a financial transaction carried out on behalf of the taxpayer by a person other than the taxpayer and, provided the taxpayer has a limited liability, the financial transaction must be related to its activities in the Slovak Republic.
Extension of entities excluded from FTT taxation
Extension of the range of entities that are not FTT taxpayers – to include public research institutions of the Slovak Academy of Sciences, the Office for Audit Oversight, the Nation’s Memory Institute , the Office of the Commissioner for Persons with Disabilities, and the Office of the Commissioner for Children.
Amendment to the definition of FTT taxpayer and penalties
Extension of the definition of FTT taxpayers to include taxpayers who have carried out a financial transaction that is not excluded from the scope of taxation on a special account intended for financial transactions that are not subject to the tax. In this context, the tax administrator shall be authorised to impose a penalty upon such a taxpayer.
The amendment will come into effect on 1 January 2026.
In view of the above amendments, a new template of the Notification on the Financial Transaction Tax has also been issued, which shall be used for the first time for the tax period of January 2026.
