New minimum tax law for multinational corporations

Minimum income tax for multinational corporations

EU Directive 2022/2523 of 14/12/2022 on ensuring a global minimum level of taxation for multinational groups and large domestic groups in the Union has been implemented into Slovak law.

With effect from 31.12.2023, a new Act No. 507/2023 on the equalisation tax to ensure a minimum level of taxation of multinational enterprise groups and large domestic groups was approved.

The law introduces a top-up tax for multinational groups and large national groups with an annual turnover of EUR 750 million or more, achieved in at least two accounting periods out of the four accounting periods immediately preceding the accounting period under analysis.

A top-up tax shall be applied if the effective tax rate does not reach 15 %.

The deadline for filing the tax return for the top-up tax shall be 15 months after the end of the tax year. The tax will be payable within the same period. The tax return will be filed electronically.

In the first transitional period, i.e. for the period starting on 31.12.2023 at the earliest, the deadline for filing the tax return will be automatically extended by 3 months. In the case of a tax return for the calendar year 2024, the deadline will therefore expire at the end of June 2026.

A fine of between EUR 1,500 and EUR 50,000 may be imposed for failure to comply with the notification obligation or for failure to file a tax return, even repeatedly.


Milan Černák

Managing Partner RSM SK
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