Top-Up Tax in Slovakia: New Obligations for Multinational Groups from 2026
The top-up tax in Slovakia will soon affect selected companies that are part of multinational groups with significant consolidated revenues.
The rules apply to groups whose ultimate parent entity reports annual consolidated revenues of at least EUR 750 million in at least two of the four accounting periods immediately preceding the relevant financial year.
Which companies are affected by the top-up tax
The top-up tax applies to Slovak entities that are members of a group meeting the revenue threshold.
In practice, this means that if the consolidated revenues of the ultimate parent entity reached or exceeded EUR 750 million in at least two years between 2020 and 2023, Slovak entities within the group will be required to assess their top-up tax liability for the 2024 financial year in 2026.
How the top-up tax works
The taxable period for the top-up tax is:
the accounting period for which the ultimate parent entity prepares consolidated financial statements, or
the calendar year.
If the effective tax rate for all Slovak entities within the group is below 15%, the difference will be collected through the top-up tax mechanism.
This ensures that multinational groups meet the global minimum tax rate of 15%.
Exemptions and safe harbour rules
The legislation includes several safe harbour rules, which may result in a zero top-up tax liability if specific conditions are met.
Additionally, certain entities are fully excluded from the scope of the top-up tax, including:
public entities,
international organisations,
non-profit organisations,
pension funds,
certain investment funds.
Filing obligations and deadlines
Taxpayers will be required to electronically submit to the tax authority:
a notification containing information necessary to determine the top-up tax, and
a tax return,
even if no top-up tax liability arises.
In certain cases, the notification may be submitted by another group entity on behalf of the taxpayer.
The deadline for fulfilling these obligations is:
within 15 months after the end of the tax period.
For the 2024 financial year, the deadline is exceptionally extended by three months:
until June 30, 2026.
The top-up tax must also be paid within the same deadline.
More details and official forms are available on the website of the Financial Administration of the Slovak Republic:
https://www.financnasprava.sk
Penalties for non-compliance
The deadline for filing the notification, submitting the tax return, and paying the top-up tax:
cannot be extended,
and cannot be waived.
Failure to comply may result in penalties:
from EUR 1,500 up to EUR 50,000,
and these penalties may be imposed repeatedly.
What this means for businesses
The introduction of the top-up tax in Slovakia represents a significant change for multinational groups.
Companies should:
assess whether they meet the revenue threshold,
evaluate their effective tax rate,
prepare for new reporting and compliance obligations.
Early preparation is essential to ensure compliance with the new rules and avoid penalties.
