When a cross-border element enters your business: a foreign subsidiary, a stake in a foreign company, a holding before a sale, moving IP or residence, or a foreign investor or buyer. A purely domestic company with Slovak clients usually does not.
Skip to contentPreparing for the consultation
- kancelaria@aksamec.sk
- +421 904 625 859
- Národná 15, 010 01 Žilina
International Tax Planning
International Tax Planning in practice
A business owner invoicing only Slovak clients from one limited company rarely needs international planning. Things change when the company sets up a subsidiary abroad, prepares for a sale, moves intellectual property or when the owner relocates to another country. That is when the rules the Slovak tax authority watches come into play: controlled foreign companies, DAC6 reporting, exit tax and transfer pricing.
We first map your income, structure and plans, then compare two or three possible scenarios, including a purely Slovak solution. For each we check the CFC rules, DAC6 reporting and pricing between related parties. Quite often a Slovak holding company turns out to be the simplest route. We are not registered tax advisers or accountants, so returns and bookkeeping are handled by partners from those professions. We represent you if a tax inspection follows.
What we help with
- Tax map of your income, structure and plans
- Comparison of two or three structuring scenarios
- Testing the CFC rules under Section 17h of the Income Tax Act
- Assessing DAC6 hallmarks and preparing the report
- Setting transfer prices and documentation
- Designing a Slovak holding company
- Representation in tax inspections
Worth knowing
DAC6: report within 30 days
A cross-border arrangement meeting any of hallmarks A to E under Slovak Act No. 442/2012 Coll. must be reported to the Slovak Financial Directorate within 30 days of being made available, ready or first implemented.
Exit tax under Section 17f
When a company moves assets or its tax residence abroad, unrealised gains are taxed. Exit tax does not apply to the sale of a share in a Slovak company as such.
Transfer pricing under Section 18
Transactions between related parties must be priced as independent parties would price them. Documentation must be provided within 15 days of a request from the tax authority.
Slovak holding company
Dividends received by a Slovak company are outside the scope of tax (Section 12(7)(c) of the Income Tax Act). Gains on selling a share are exempt under Section 13c for a holding of at least 10% kept for 24 months, with substantive functions performed in Slovakia.
Common questions
- Yes, if the arrangement meets at least one of hallmarks A to E under Slovak Act No. 442/2012 Coll. The deadline is 30 days. Reporting falls primarily on the lawyer or tax adviser, or on the taxpayer where professional secrecy applies.
- Often, yes. A Slovak parent company does not pay tax on dividends received, and gains on selling a share are exempt under the conditions of Section 13c, without the cost of a real presence abroad.
Related articles
Articles are in Slovak.
What to prepare for your consultation
Tick what you already have. You can print the list or save it as a PDF. Your ticks are remembered only in your browser.
For every matter
Also for this area
0 of 8 ready
Discuss your matter with a lawyer
In a consultation we assess your situation, suggest a way forward and tell you what costs to expect.
€90 incl. VAT, 30 minutes, in person or online
This page is for general information, reflects Slovak law at the time of writing and is not a substitute for advice on your particular matter.