Source Draft law in Slovakian
Briefing Document: Slovak Tax and Accounting Law Amendments (2025-2030)
This briefing document summarises the key themes, ideas, and factual information regarding the upcoming amendments to Slovak tax and accounting laws, effective between 2025 and 2030, drawing from the provided legislative excerpts and explanatory guides. The overarching aim of these amendments is to enhance tax administration, combat tax evasion, and significantly digitalise invoicing and data reporting processes.
I. Main Themes
- Digitalisation of Tax Administration (E-Invoicing and Data Reporting): A central theme is the widespread shift towards mandatory electronic invoicing and detailed data reporting for both domestic and cross-border transactions. This aims to create a more transparent and efficient tax system.
- Combating Tax Evasion: New measures, particularly “Ex officio group registration,” are designed to proactively address and prevent tax avoidance schemes.
- Enhanced Tax Authority Powers and Oversight: The Financial Directorate and Tax Offices are granted expanded powers, including the ability to mandatorily register tax groups and enforce stricter reporting requirements, supported by significant fines for non-compliance.
- Harmonisation with EU Directives: The amendments are influenced by EU directives regarding VAT rules for the digital age and reporting obligations, ensuring alignment with broader European digital taxation initiatives.
- Administrative Burden Shift and Compliance Focus: While aiming for efficiency, these changes place substantial new compliance burdens on taxpayers, requiring significant adjustments to their accounting and invoicing systems.
II. Most Important Ideas and Facts
A. Key Amendments to the VAT Act (Act No. 222/2004 Coll.)
- Ex Officio Group Registration (Section 4c):
- Objective: To counter tax avoidance. “The primary objective of ‘Ex officio group registration’ is to address situations where multiple group members conduct business with the main aim of avoiding tax payments.” (Slovak Tax and Accounting Law Amendments: 2025-2030 Guide)
- Trigger: The Tax Office Banská Bystrica can initiate this registration if evidence suggests businesses are forming groups primarily to avoid tax.
- Impact: Upon finalisation of the decision, the group becomes a single tax payer, and “the individual tax identification numbers of group members, if assigned in national territory, cease to be valid.” (Slovak Tax and Accounting Law Amendments: 2025-2030 Guide)
- Effective Date: 1 January 2026.
- Electronic Invoicing (Sections 71-76a, 85n):
- New Definition (Section 71(1)(b)): An “electronic invoice” must be a document or notification that allows for “automated and electronic processing, and… in a data structure in accordance with the technical standard for electronic invoicing and with the list of its syntaxes according to a specific regulation.” (sk.pdf)
- Mandatory Preparation (Section 71(4)): “An invoice shall now be drawn up as an electronic invoice, unless the law permits a simplified or other form.” (Slovak VAT Act: Electronic Invoicing and Reporting Amendments) Crucially, “The preparation of an electronic invoice is not subject to the consent of the recipient of the supply.” (sk.pdf)
- Recipient Consent for Sending (Section 71(4)): Consent is still required if the e-invoice is “sent by means other than the delivery service.” (sk.pdf)
- Simplified Invoices (Section 71(6)): Apply to transactions under EUR 100 (including tax) or up to EUR 400 for e-Kasa Client cash register documents/unmanned refuelling machine documents. These do not require all full e-invoice data.
- Certified Delivery Service Providers (Section 76a(2)): These providers must ensure automated compliance checks, high reliability in sender/addressee identification, authenticity, integrity, legibility, and proof of dispatch/delivery/receipt. They also have “information obligations pursuant to Sections 80, 80a and 85n.” (sk.pdf)
- Timelines:Initial Mandatory E-Invoicing for Domestic Supplies (Section 85n(2)): From 1 January 2027, payers supplying goods/services domestically to taxable or non-taxable legal persons (with a registered office/residence in Slovakia) must issue electronic invoices.
- Full Implementation (Sections 71-76): 1 July 2030.
- Data Reporting Obligations (Sections 80, 80a, 85n):
- Cross-Border Supplies (Section 80): Payers must report specific data to the Financial Directorate for cross-border supplies, acquisitions, and related payments. This includes tax-exempt goods, movement of goods, and various services with a place of supply in another Member State, including triangular trade. Data varies by transaction type but often includes supplier/customer TINs and invoice data.
- Domestic Supplies (Section 80a): Taxpayers must report data for domestic supplies of goods and services (excluding those covered by Section 80 and certain tax-exempt supplies), including supplier/customer TINs (or name if no TIN) and specific invoice data.
- Reporting Timelines: Data must be reported “at the time of issuing an electronic invoice or on the last day of the deadline for issuing an electronic invoice” or “no later than five days from the date of issue of the electronic invoice or from the date of expiry of the deadline.” (sk.pdf, Sections 80(6), 80a(6)). For recipients, data must be reported “no later than five days from the date of receipt of the electronic invoice.” (sk.pdf, Sections 80(7), 80a(7)).
- Replacement of Control Statement: The previous reporting obligation via “control statements (Section 78a)” is deleted from 1 July 2030, largely replaced by the new e-invoicing and data reporting. (sk.pdf, Section 47)
- Effective Dates:Initial mandatory e-invoicing and related reporting for domestic supplies: 1 January 2027.
- Full data reporting (Sections 80, 80a) and full e-invoicing provisions: 1 July 2030.
- Invoice Issuance Deadlines: General invoice issuance deadlines are shortened “from the 15th day to the tenth day” (sk.pdf, Sections 19(8)(a), 20(1)(a), 73(1)). Summary invoices must be drawn up within “ten days of the end of the calendar month.” (sk.pdf, Section 75).
- Fines for Non-Compliance: Significant fines up to EUR 10,000 (and up to EUR 100,000 for repeated offences) can be imposed for failure to communicate required data, or for providing incomplete/incorrect information.
B. Key Amendments to the Tax Administration Act (Act No. 563/2009 Coll.)
- Expanded Tax Administrator Competence: Tax administrators can now act “in relation to a taxable entity to which another tax administrator is competent” (sk.pdf, Art. II, Section 36(3)), and decisions on charges/liens can be made by non-competent tax administrators (excluding municipalities). (sk.pdf, Art. II, Sections 81(11), 82).
- Interim Measures and Excess Deduction Reimbursement (Section 79(12)): The time limit for reimbursing excess deductions “shall not run from the date of issuance of the decision imposing an interim measure… until the date on which the decision imposing the interim measure was revoked or until the date on which the interim measure ceases to be effective.” (sk.pdf)
- Effective Date: 1 January 2026 for general amendments; 1 January 2027 for interim measures.
C. Key Amendments to the Accounting Act (Act No. 431/2002 Coll.)
- Electronic Format Requirement (Section 35(2)): If laws (including the amended VAT Act) mandate an electronic format for accounting records, these records “shall also keep the accounting record in this electronic format.” (sk.pdf)
- Transitional Provisions (Section 39zf): Entities obliged to submit annual reports and general meeting records under previous rules will no longer be required to do so after 31 December 2025.
- Effective Date: 1 January 2026 for transitional provisions; 1 January 2027 for electronic format mandate.
D. Key Amendments to the Public Procurement Act (Act No. 343/2015 Coll.) & Guaranteed Electronic Invoicing Act (Act No. 215/2019 Coll.)
- Mandatory E-Invoice Acceptance (Public Procurement): Contracting authorities and entities are “obliged to ensure that he or she is able to receive electronic invoices through a delivery service… and to process them further.” (sk.pdf, Act No. 215/2019 Coll., Section 2(1)).
- Public Procurement Identifiers on E-Invoices: Electronic invoices relating to public procurement “shall also indicate the number of the contract notice” or other relevant public procurement identifiers. (sk.pdf, Act No. 215/2019 Coll., Section 2(2)).
- Effective Date: 1 January 2026 for Public Procurement Act deletion; 1 January 2026 for Guaranteed Electronic Invoicing Act amendments.
III. Timeline Summary
- 2025: EU Directives on VAT rules for the digital age (March 11) and reporting obligations (July 18) issued, influencing future amendments.
- 1 January 2026:General effective date for most initial amendments, including “Ex officio group registration.”
- Amendments to Tax Administration Act allowing broader tax administrator competence and decisions on charges/liens.
- Transitional provisions for Accounting Act (annual reports).
- Public Procurement Act (deletion of Section 154(5)).
- Guaranteed Electronic Invoicing Act (obligations for contracting authorities/entities to accept e-invoices and include procurement identifiers).
- 1 January 2027:Initial mandatory electronic invoicing for domestic supplies by payers (Sections 4, 4b, 4c) to taxable/non-taxable legal persons in Slovakia.
- Transitional definition of electronic invoice (Section 85n(4)) comes into effect.
- New reporting obligations for tax representatives for cross-border data.
- Tax Administration Act amendment regarding interim measures and excess deductions.
- Accounting Act amendment requiring electronic format for accounting records if mandated by law.
- 1 July 2030:Full implementation of comprehensive electronic invoicing (Sections 71-76) and detailed data reporting obligations (Sections 80, 80a).
- Mandatory electronic invoices without recipient consent for preparation.
- Updated definition of electronic invoice (Section 71(1)(b)) fully effective.
- Simplified invoice rules (EUR 100/400 thresholds) fully effective.
- Full obligations for certified delivery service providers.
- New data reporting for cross-border (Section 80) and domestic (Section 80a) supplies fully in force.
- Deletion of the Control Statement (Section 78a).
- Shortened invoice issuance and reporting deadlines (e.g., 10th day for issuance, five days for reporting).
These amendments represent a significant overhaul of the Slovak tax and accounting landscape, pushing towards greater transparency, efficiency, and stricter enforcement, aligning with broader European digital tax trends.
- See also
- Join the Linkedin Group on Global E-Invoicing/E-Reporting/SAF-T Developments, click HERE
