Entrepreneurs’ Telegram October 2025

Dear clients and partners,

In the last issue of mailingLeitner Slovakia, we provided you with an overview of the approved consolidation measures and their impact on wages and social security contributions. In this issue, we will continue with an outline of further changes in the area of direct taxes and special contributions introduced by the consolidation package, as well as other related measures.

The changes in the VAT Act will be summarized in the next issue of mailingLeitner Slovakia.

We would like to draw your attention in particular to:

• New range of minimum corporate income tax

• Specific provisions for certain business sectors

• Changes to the super deduction for investments

• Tax amnesty

• Changes to the financial transaction tax

• A New Era of Document Archiving – Electronic, Efficient, and Without Duplicates

New range of minimum tax for the largest companies

The minimum corporate income tax was reintroduced in 2024. Starting from the year 2026, a new bracket of the minimum tax license will apply to the largest companies with taxable revenues exceeding EUR 5 million. In 2025, these companies were required to pay a minimum of EUR 3.840, whereas from 2026 this amount will increase to up to EUR 11.520.

Specific taxation and levies for certain business sectors

Increase of the special levy for collective investment

The rate of the special levy for investment and management companies, as well as pension and supplementary pension management companies, will more than triple – from 4.36% to 15%.

Higher taxation of non-life insurance and gambling

From January 1, 2026, the tax rate on non-life insurance products will increase from 8% to 10%.

A new taxation mechanism will also apply to bank fees charged on deposits made by payment cards into gambling accounts (so-called player accounts). Such bank revenues from gambling fees will be subject to a special tax base at a rate of up to 54%. The special levy on online games will also increase from the current 27% to 30%.

Introduction of a levy on primary materials

Companies that extract gravel, sand, building stone and sand-gravel mixes should prepare for new costs. A new levy of EUR 1.35 per ton will be introduced for new extractions starting from January 1, 2026. The details concerning the payment of the levy on extracted primary raw materials, as well as the method of calculation and payment, will be set out in a government decree of the Slovak Republic, which has not yet been adopted.

Changes to the super deduction for investments

The “super deduction for investments” is a temporary tax incentive introduced in 2022 for entrepreneurs who invest in assets with higher added value associated with Industry 4.0 (digitalization, automation, robotization). The original legislation stipulated that the investment plan drawn up by the taxpayer and for which the super deduction could be claimed should be for a maximum of 6 years until 2027. The current amendment has extended the possibility of claiming the super deduction to 9 years, until 2030. The extension of the investment period will apply to both existing and new investment plans.

Tax amnesty

A newly approved government regulation introduces the cancellation of tax arrears corresponding to unpaid sanctions related to paid taxes and waives penalties and late payment interest, effective from 1 October 2025. The measure, essentially a form of tax amnesty, allows taxpayers with outstanding tax arrears as of September 30, 2025, or those who have failed to file a tax return by that date, to avoid fines and default interest. To qualify, taxpayers must, during the designated substitute period from January 1 to June 30, 2026, either settle the outstanding tax arrears or submit the required (original or additional) tax return and pay the resulting tax liability.

Changes to the financial transaction tax

On September 30, 2025, parliament approved an amendment to the Act on Financial Transaction Tax, which will take effect on January 1, 2026. Under the new rules, the tax will apply only to legal entities; sole traders will no longer be subject to the financial transaction tax.

The amendment provides legislative clarification regarding taxpayers with limited and unlimited tax liability. Legal entities with their registered seat in the Slovak Republic will be subject to the financial transaction tax in full. Foreign legal entities will incur tax liability only if they conduct activities in the Slovak Republic through a permanent establishment or hold an account with a Slovak payment service provider.

For the first time, the concept of a permanent establishment is explicitly defined in the law. Foreign entities performing one-off activities in Slovakia will be required to pay tax if their activities exceed 15 days within a calendar month. This same time limit will apply to construction and installation projects.

Other activities that may create a permanent establishment include, for example, the provision of services, operation of e-shops, mediation of contracts, or situation where a foreign entity has an insured risk located in Slovakia (such as ownership of real estate) or where it has a branch established in Slovakia.

The amendment also introduces a definition of “recharged cost.” This term refers to the amount of a financial transaction carried out on behalf of a taxpayer by another person. In the case of a foreign company, the financial transaction must be related to activities carried out within Slovak territory.

We have prepared several newsletters on this topic in the past – you can find them here.

A New Era of Document Archiving – Electronic, Efficient, and Without Duplicates

As of October 15, 2025, an amendment to the Archives and Registries takes effect, fundamentally changing the way companies, municipalities and institutions record and store their documents. The purpose of this amendment is to simplify administrative processes, promote digitalization, and increase the efficiency of record management.

Key Changes Introduced by the Amendment

• Transformation of Registry Records – Allows the replacement of paper documents with electronic versions without the need for a disposal procedure.
• Elimination of Duplicate Archiving – Removes the obligation to store documents simultaneously in both paper and electronic form.
• Harmonised Rules for Registry Management– Reduces administrative burden and streamlines internal processes.
• Electronic Authorization -Enables the use of electronic initials in compliance with the e-Government Act.
• Separate Disposal Procedure -Allows certain documents to be disposed of before the end of their retention period.

From an accounting and tax perspective, the amendment enables companies to store accounting records exclusively in electronic form, provided that their authenticity, integrity, and readability are ensured throughout the entire retention period. Businesses can now fully digitalize invoices, contracts, and other accounting documents without the need to retain paper originals.

For records with long retention periods (sometimes up to 70 years), electronic archiving is significantly more efficient — saving physical space, time, and administrative costs. A properly configured e-archive system allows for automatic tagging of documents with their disposal date and easy monitoring of retention periods in accordance with the applicable legislation.

We are ready to advise you on how to set up your electronic archive to ensure full compliance with accounting and tax regulations while optimizing your internal processes.

Contact us – our experts will provide you with in-depth know-how and individual advice.