The Top-up Tax Act is awaiting amendment

The Ministry of Finance of the Slovak Republic has submitted a draft amendment to Act No. 507/2023 Coll., on the Top-up Tax to Ensure a Minimum Level of Taxation of Multinational Groups of Companies and Large National Groups, which we have already informed you about in previous articles in our TPA Newsletter.

The proposed amendment to the Act was created due to the need to transfer into Slovak legislation the administrative guidelines to the global model rules against tax base distortion, which were adopted by the OECD/G20 Inclusive Framework.

The changes proposed in the Act are mainly technical and are complementary to existing provisions. The changes include:

• Clarifications and additions within the calculation of the underlying entity’s eligible income or eligible loss and within the calculation of the amount of adjusted included taxes,
• Clarification of established definitions,
• Addition of rules for calculating the amount of excluded income on the basis of economic substance,
• Introduction of simplified calculations for insignificant entities.

The amendment to the Act is proposed to take effect as of 31 December 2024.