Amendment to the Slovak Tax Code: New Penalty Rules from 2026
As of January 1, 2026, an amendment to Act No. 563/2009 Coll. on the administration of taxes (Tax Code) has entered into force. This amendment introduces significant changes to the penalty regime for breaches of tax obligations.
The new rules affect virtually all key obligations of taxpayers under the Tax Code.
Which obligations are affected
The amendment applies to breaches of the following obligations:
failure to file a tax return within the statutory deadline or within the deadline set by the tax authority,
failure to fulfil registration obligations,
failure to meet notification obligations,
failure to comply with obligations imposed by a tax authority decision or other non-monetary obligations under the Tax Code or specific regulations.
Increase in minimum penalties
One of the key changes introduced by the amendment is the increase in minimum penalties.
The lower limits have been raised:
from EUR 30 or EUR 60,
to a new unified minimum of EUR 100.
This change aims to strengthen the preventive effect of penalties and encourage compliance with tax obligations.
Increase in maximum penalties
The amendment also significantly increases the maximum penalty thresholds.
The new limits are as follows:
Failure to file a tax return
up to EUR 30,000,
up to EUR 60,000 if the return is submitted only after a request from the tax authority.
Failure to fulfil registration obligations
up to EUR 30,000.
Failure to meet notification or other non-monetary obligations
up to EUR 10,000.
This category includes, for example, failure to submit transfer pricing documentation or failure to comply with obligations imposed by the tax authority.
When the new penalties apply
The new penalty regime will apply only to breaches that occur after December 31, 2025.
If a violation was committed in 2025, the penalty will be assessed under the previous rules, even if the decision is issued in 2026.
This ensures compliance with the principle of non-retroactivity.
New incentive mechanism
The amendment also introduces a penalty reduction mechanism.
If a taxpayer pays the assessed tax or tax difference (e.g. following a tax audit) within 15 days from the delivery of the decision, the penalty will be reduced.
In such cases:
the penalty is reduced to two-thirds of the original amount.
This rule will apply for the first time to decisions delivered after December 31, 2025.
What this means for businesses
The amendment significantly tightens the penalty regime and increases financial risks for non-compliance.
From 2026, the rules for imposing penalties for breaches of tax obligations are changing, with both minimum and maximum penalties increasing.
Businesses should therefore:
review their tax compliance processes,
ensure timely fulfilment of all obligations,
minimize the risk of penalties under the new regime.
