The National Council of the Slovak Republic has approved a bill that amends the VAT Act (Act No. 222/2004 Coll. on the Value-added Tax, as amended) and some other acts (the Act on the Administration of Taxes (Tax Code); the Mineral Oil, Tobacco Products, Alcoholic Beverages, Electricity, Coal, and Natural Gas Excise Tax Acts, and the Act on Using Electronic Cash Registers).
Below, we present a brief overview of the most important changes to the VAT Act introduced by its most recent amendment, arranged chronologically by their effective dates. For most provisions in individual parts of the amendment, the effective date has been postponed to 1 January 2025.
VAT registration of a domestic taxable person under § 4
Under the new § 4, if a taxable person achieves a turnover of €50,000 in the current calendar year, it becomes a VAT payer as of 1 January of the following calendar year, unless an event occurs due to which the taxable person becomes a VAT payer before that date (e.g. it becomes a legal successor of a VAT payer that is about to cease to exist without liquidation, acquires a business or a part thereof, etc.). However, a taxable person may become a VAT payer immediately by stating such a decision in the registration form.
The amendment also introduces a new turnover amount of €62,500 which, if exceeded, will cause the taxable person to immediately become a VAT payer by the delivery of goods or the provision of a service by which this turnover is exceeded.
According to the amended provision, turnover shall be determined for a calendar year, instead of no more than 12 preceding consecutive calendar months.
An application for VAT registration must be filed within 5 working days as of the day on which an event occurred based on which the taxable person became a VAT payer. Within 10 days, the tax office shall issue a resolution on registration with a declarative nature, i.e. it only confirms the VAT payer’s registration as of the day on which an event occurred based on which the taxable person became a VAT payer.
Providers of exempt financial and insurance services and real estate rental services shall again be obliged to register; however, they will not have to file a VAT return and a control statement (unless they carry out another supply which would cause them to become a person liable to pay VAT).
The conditions for voluntary VAT registration remain unchanged.
VAT registration of a foreign taxable person under § 5
A foreign taxable person that does not have a seat or fixed establishment in Slovakia shall become a VAT payer upon carrying out a taxable transaction subject to VAT in Slovakia (except for certain transactions specified in the VAT Act). Fixed establishments of foreign entities seated in the EU that are small enterprises and were allocated a VAT ID with the suffix “EX” for Slovakia, will be able “not to become a VAT payer”.
Similar to the domestic VAT payer registration, a foreign entity shall also be obliged to file an application for VAT registration within 5 working days as of the day on which an event occurred based on which the taxable person became a VAT payer. Within 10 days, the tax office shall issue a resolution on registration with a declarative nature, i.e. it only confirms the VAT payer’s registration as of the day on which an event occurred based on which the taxable person has become a VAT payer.
Finance lease
Under EU law and the established judicature of the Court of Justice of the European Union, the VAT treatment of the transfer of goods based on a lease agreement with the agreed right to purchase the leased item will be changed if making use of the purchase right is economically the only rational choice for the lessee at the time of the conclusion of the lease agreement. As of 1 January 2025, such transfer of the ownership title to a leased item will constitute a supply of goods subject to tax, and the tax must be paid on the total value of the lease at its inception, and not on individual instalments during the entire lease term as is currently the case (based on the current VAT treatment as the supply of a service).
The new VAT treatment will apply to contracts concluded after 31 December 2024.
Input VAT deduction based on a document other than an invoice
The amendment also introduces the option to deduct VAT when acquiring goods from another EU member state based on a document other than an invoice that confirms the acquisition of the goods and shows the amount of the tax liability that must be reported.
Late VAT registration
The current rules stipulate that if a VAT payer fails to file an application for VAT registration in time, they must only file one VAT return for the entire period in which they should have been a VAT payer and report all transactions therein. Under the new wording, a taxable person will be obliged to submit a VAT return along with a control statement for each month separately and in chronological order, in which all transactions for which a tax liability arose in the given month must be listed. When the conditions are met, the deduction of the related input VAT may be claimed in the VAT returns.
The amended provisions will increase the administration burden and the penalties for delayed VAT registration – there will be sanctions for non-compliance with the registration obligation, delayed submission of VAT returns, control statements, and the EC sales lists, where appropriate.
Invoices
The following changes to invoicing have been approved:
- If a VAT payer is not allocated a VAT ID within the standard 15-day period for issuing an invoice (but they complied with the registration / notification obligation), they will be obliged to issue an invoice within 5 working days of the day on which they received the resolution on registration.
- An input VAT deduction based on a document issued by the ‘cash register client’ system is currently only permitted when the amount on the document (including VAT) does not exceed €1,000 when paid in cash, or €1,600 when paid using a payment card. To improve control and reduce the number of multiple deductions from one sales slip, this maximum amount will be decreased and unified to €400.
Small enterprises
Slovakia is obliged to transpose Council Directive (EU) 2020/285 as regards the special scheme for small enterprises. The objective is to ensure equal treatment for established and non-established taxable persons as regards the exemption of the conduct of economic activities from VAT up to a certain turnover.
In this context, Member State annual turnover (€62,500 in the current calendar year and €50,000 in the previous calendar year) and Union annual turnover (€100,000) are introduced. Taxable persons who do not achieve these turnovers will be allocated a special VAT ID with a suffix ‘EX’ that will allow them to deliver goods and services across the entire EU with VAT exemption – i.e. as a taxable person that is not a VAT payer.
The amendment introduces special reporting procedures for domestic and foreign taxable persons who apply the scheme for small enterprises, as well as conditions for the inception and termination of the application.
Other important changes
- The obligation to return deducted input VAT in the event of theft is extended to any illegally appropriated goods.
- The place of delivery of cultural, educational or entertainment services, including admission to events and supplementary services is changed if delivered to a taxable or non-taxable person online / virtually.
- In the event of outstanding liabilities, the obligation to return deducted input VAT will arise no earlier than in the taxable period in which the 101st day after the due date falls (currently 100 days after the due date).
- The application of VAT exemption when delivering goods from Slovakia to another EU member state is clarified according to which a VAT exemption may not be applied if the supplier of goods is not a VAT payer.
Reverse charge when importing goods
The current provision in the VAT Act that introduces a reverse charge when importing goods is ineffective, so its modification was necessary. As of 1 July 2025, the reverse charge may be applied by a VAT payer in the name and at the expense of which the customs declaration is submitted and who is, at the time when the tax liability regarding importing goods arises:
- a) established in Slovakia (i.e. has its seat, place of business, fixed establishment or domicile in Slovakia);
- b) registered for VAT purposes in Slovakia (§ 4 or § 4b for a VAT group);
- c) an Authorised Economic Operator (i.e. has a valid permit that grants them such a status).
A VAT payer who applies a reverse charge when importing goods shall be obliged to calculate VAT and enter it in the VAT return for the taxable period in which the tax liability arose and will also be entitled to deduct input VAT in the same taxable period (if conditions set out in § 49 and § 51 are met).
As of 1 January 2026, the group of taxable persons who may apply the reverse charge when importing goods will be extended to foreign taxable persons registered for VAT purposes in Slovakia (§ 5). It is also specified that the reverse charge may only be applied within the centralised clearance system. The special tax payment method is introduced for the import of goods within the centralised clearance system if the importer does not meet the conditions for reverse charge application. In such a case, the customs office shall immediately calculate the tax amount and notify the person liable to pay the tax (§ 69 Section 8) of the tax amount, which shall be due within 10 days of the day on which the tax amount was notified.
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