Reviewed by the editorial team of Symbol Consulting DMCC
The corporate income tax rate in Slovakia is a single number (10, 21 or 24 %) applied to the whole tax base reduced by the tax loss. It is selected by taxable revenue (zdaniteľné príjmy (výnosy)) for the tax period, meaning the total of revenues in line 560 of the tax return, not profit. Since 1 January 2026 the same quantity also places the company in one of five minimum tax bands, from 340 to 11 520 euros.
This material combines two provisions of Act No. 595/2003 Coll. on Income Tax, § 15 and § 46b, with two 2026 methodological guidelines of the Financial Directorate of the Slovak Republic and works out what follows for a company whose 2026 tax period closes in under three months; the top-up tax of multinational groups under the Pillar Two rules is outside its scope.
Why the question about the rate on the first 100 000 euros of profit has no answer in the Act
Act No. 595/2003 Coll. on Income Tax has no profit brackets for a legal entity, so no rate “on the first 100 000 euros” can be found in it. The rate is selected once per tax period according to taxable revenue (zdaniteľné príjmy (výnosy)) and applies to the whole tax base. § 15 reserves the splitting of the base into parts with different rates for individuals only.
A commercial English-language text for company founders nevertheless answers the question in exactly this form. The Arrive guide of 7 September 2026 describes whom Slovakia suits with this sentence: “A founder who wants a low-capital, credible EU and eurozone operating company with a 10 % rate on the first EUR 100 000, and who can handle Slovak notarisation, electronic-signature and translation formalities — or who is already inside the EU eIDAS system, in which case most of that friction disappears” (commercial guide Arrive, 7. 9. 2026).
The sentence is quoted in full; the numbers are rewritten in Slovak notation. The same guide gives the minimum tax as a range from 340 to 11 520 euros by revenue band; the deviation concerns only how the rate is applied.
For a foreign manufacturer planning the tax of a Slovak s.r.o. subsidiary on the basis of such a sentence, this is the wrong question. The right one is: what taxable revenue will the company achieve for the 2026 tax period? The answer sets the rate for the whole tax base and the minimum tax band the company will pay if it reports a loss or a low tax. Profit decides only at the second step, and only the base to which the selected rate is applied.
How § 15 assigns the rate: taxable revenue, not profit
Section 15(b), point 1, of Act No. 595/2003 Coll. on Income Tax sets a 10 % rate for a legal entity whose taxable revenue for the tax period does not exceed 100 000 euros, a rate of 24 % where it exceeds 5 000 000 euros, and a rate of 21 % for all others. Each is applied “to the tax base reduced by the tax loss” (primary source Slov-lex, version effective from 1. 1. 2026).
The difference from an individual is visible in the wording of the Act itself. For an individual, § 15(a) repeats the formula “on the part of the tax base which…” for each of the four bands of 19, 25, 30 and 35 %. For a legal entity the formula is absent; point 1c. speaks of a taxpayer “who achieved taxable revenue exceeding 5 000 000 euros for the tax period”, not of a part of the base above some threshold.
Total taxable revenue is reported in line 560 of the tax return. In its guideline on advance payments, the Financial Directorate of the Slovak Republic describes where it comes from: under double-entry bookkeeping from table F, under IFRS from tables G1 to G3, and for a non-resident from table H; revenues that are outside the scope of the tax or exempt from it are then excluded (primary source Financial Directorate of the Slovak Republic, methodological guideline 6/DZPaU/2026/MP of 13. 2. 2026).
The same guideline shows the consequence in figures. In its example 7 a company has taxable revenue above 5 000 000 euros and a tax base of 1 250 000 euros; the tax for advance-payment purposes is 300 000 euros, i.e. the whole base times 24 %. Under a bracket reading, nothing would be taxed at 24 %, because the tax base does not reach the 5 000 000 euro threshold.
According to the guideline, the 10 % and 24 % rates first applied to a tax period beginning no earlier than 1 January 2025, and the 100 000 euro threshold is inclusive. The version of the Act effective from 31 December 2026, which Slov-lex already publishes, changes neither § 15 nor § 46b.
Minimum tax under § 46b: five bands by taxable revenue
A company pays the minimum tax of a legal entity under § 46b of Act No. 595/2003 Coll. for a tax period with a tax loss or with tax, after reliefs and foreign tax credit, below the amount set for its band. The band is determined by taxable revenue; since 1 January 2026 there are five bands, with amounts of 340, 960, 1 920, 3 840 and 11 520 euros.
On 18 August 2026 the Financial Directorate of the Slovak Republic published a methodological guideline that states the link directly: “The amount of the minimum tax depends on the amount of taxable revenue the taxpayer achieved for the tax period” (primary source Financial Directorate of the Slovak Republic, guideline on the minimum tax, 18. 8. 2026). In the list of guidelines and in the file name it carries number 12/DZPaU/2026/MP; the PDF header gives it number 6/DZPaU/2026/MP, under which the February guideline on advance payments is also listed.
According to the guideline, the new 11 520 euro band applies for the first time to the 2026 tax period, or to the 2026/2027 financial year. At the same time the preceding band narrowed: the 3 840 euro amount now covers only taxable revenue above 500 000 euros up to and including 5 000 000 euros, whereas for 2024 and 2025 it applied to all revenue above 500 000 euros.
Further rules of § 46b as in force from 1 January 2026 set payment, credit and reduction. The minimum tax is payable within the deadline for filing the tax return. The positive difference between the minimum tax and the calculated tax may be credited in at most three following tax periods, and only against the part of the tax that exceeds the minimum tax. For a tax period shorter than twelve months, 1/12 of the amount is paid for each month, and a company in which persons with disabilities make up at least 20 % of the average registered headcount pays half.
The guideline illustrates the new band with example 3: a company with taxable revenue of 5 200 000 euros reports a tax of 9 000 euros for 2026 but pays the minimum tax of 11 520 euros, by 31 March 2027. It may credit the difference of 2 520 euros in 2027 to 2029. No advance payments arise from the minimum tax; the company in the example will pay quarterly advances of 2 250 euros in 2027, derived from the 9 000 euro tax.
Six taxable revenue intervals and the base below which minimum tax applies
Rate thresholds and minimum tax thresholds together split taxable revenue into six intervals. The 100 000 euro threshold changes only the rate, the 50 000, 250 000 and 500 000 euro thresholds change only the minimum tax, and since 2026 the 5 000 000 euro threshold changes both at once. Neither the Act nor the Financial Directorate of the Slovak Republic guidelines list them in one table.
| Taxable revenue for the 2026 tax period | Rate under § 15 | Minimum tax under § 46b | Base below which minimum tax is paid |
|---|---|---|---|
| up to 50 000 euros inclusive | 10 % | 340 euros | 3 400 euros |
| over 50 000 up to 100 000 euros | 10 % | 960 euros | 9 600 euros |
| over 100 000 up to 250 000 euros | 21 % | 960 euros | 4 571,43 euros |
| over 250 000 up to 500 000 euros | 21 % | 1 920 euros | 9 142,86 euros |
| over 500 000 up to 5 000 000 euros | 21 % | 3 840 euros | 18 285,71 euros |
| over 5 000 000 euros | 24 % | 11 520 euros | 48 000 euros |
The last column is Symbol Consulting’s own calculation: the minimum tax divided by the interval’s rate. It is the tax base below which the minimum tax replaces the calculated tax, assuming no reliefs under § 30a or § 30b and no credit for tax paid abroad. Reliefs lower the calculated tax, so for their recipients the threshold moves up.
At taxable revenue just above 5 000 000 euros, the 48 000 euro threshold corresponds to a tax base of 0,96 % of revenue. At such turnover and a thin margin, 11 520 euros is thus paid whether the calculated tax is lower or zero; the difference can be credited only over the next three years, and only if the tax then exceeds the minimum tax.
As the rate applies to the whole base, crossing a threshold is a jump. With a tax base of 30 000 euros, taxable revenue of 100 000 euros means a tax of 3 000 euros, revenue of 100 001 euros a tax of 6 300 euros. With a base of 300 000 euros, revenue of 5 000 000 or 5 000 001 euros means a tax of 63 000 or 72 000 euros. Both pairs are Symbol Consulting’s own calculation.
What the bracket reading changes: four model companies
The difference between the bracket reading of the rate and the wording of § 15 of Act No. 595/2003 Coll. is zero for a company below 100 000 euros of taxable revenue and grows with the tax base. For a manufacturer with taxable revenue of 6 000 000 euros and a base of 400 000 euros, the bracket calculation comes out 23 000 euros below the tax under the Act, almost a quarter lower.
| Company | Taxable revenue | Tax base | Tax under § 15 and § 46b | Profit-bracket calculation | Difference |
|---|---|---|---|---|---|
| A | 70 000 euros | 15 000 euros | 1 500 euros (10 %) | 1 500 euros | 0 euros |
| B | 1 200 000 euros | 150 000 euros | 31 500 euros (21 %) | 20 500 euros | 11 000 euros |
| C | 6 000 000 euros | 400 000 euros | 96 000 euros (24 %) | 73 000 euros | 23 000 euros |
| D | 5 200 000 euros | 37 500 euros | 9 000 euros (24 %); payable minimum tax 11 520 euros | 3 750 euros; payable minimum tax 11 520 euros | 5 250 euros in calculated tax; 0 euros in payment |
Companies A to C are models; their tax and bracket calculations are Symbol Consulting’s own calculation. The bracket calculation for B: 100 000 euros times 10 % plus 50 000 euros times 21 %, totalling 20 500 euros. For C: 100 000 euros times 10 % plus 300 000 euros times 21 %, totalling 73 000 euros; under the bracket reading the 24 % rate is never applied, because the tax base does not reach 5 000 000 euros. Company D takes its figures from examples 3 and 4 of the Financial Directorate of the Slovak Republic guideline of 18 August 2026.
Company D shows a subtler difference. The calculated tax differs by 5 250 euros between the two readings, but the payment is 11 520 euros in both cases, because the minimum tax applies. The difference surfaces only in the credit: a reader of the bracket calculation will carry forward 7 770 euros for 2027 to 2029 instead of the 2 520 euros stated in the guideline, and will thus overstate the amount by which the tax is reduced in later years.
The origin of the reading is partly linguistic. English-language advisory summaries translate zdaniteľné príjmy (výnosy) as “taxable income”; PwC, for example, writes that the 10 % rate applies to legal entities “whose taxable income does not exceed EUR 100 000 in the tax period” (advisory source PwC Worldwide Tax Summaries, reviewed 9. 9. 2026). The wording follows the Act and is correct. In the Slovak text, however, revenues and the tax base are two different concepts, while in the English phrase the difference between them disappears.
That English can be written without this shift is shown by the ADVISON firm’s guide of 29 August 2026, which sums up the rule in a section heading “Revenue selects the rate; profit is not the tax base” (advisory source ADVISON, 29. 8. 2026). Of the sources used, only the Arrive sentence quoted above departs from the wording of the Act.
Who does not pay the minimum tax and what applies to a foreign company’s permanent establishment
A new company does not pay the minimum tax for the tax period in which it was created and for which it files a tax return for the first time; the exemption does not cover the legal successor of a company dissolved without liquidation. This is laid down in § 46b(7)(a) of Act No. 595/2003 Coll. on Income Tax (primary source Slov-lex, version effective from 1. 1. 2026).
The Financial Directorate of the Slovak Republic illustrates the exemption with an s.r.o. entered in the commercial register on 10 June 2025, which reported a loss for the period to 31 December 2025 and paid no minimum tax. No comparable exemption exists for the rate: § 15 applies from the first tax period, and the rate in it is set by the taxable revenue achieved since the company was created.
For a foreign company without a Slovak s.r.o. subsidiary, the minimum tax arises through a permanent establishment. According to the guideline of 18 August 2026, it is paid by a non-resident with a registered branch that constitutes a permanent establishment, and by a non-resident with an unregistered permanent establishment, if the tax on income attributable to the establishment is lower than the minimum tax. A branch that does not constitute a permanent establishment and has no other taxable income from Slovakia pays no minimum tax.
For the first year of an establishment, the guideline offers an interpretation using the example of a Czech legal entity that registered a branch constituting a permanent establishment on 15 October 2025. The Financial Directorate of the Slovak Republic applies the first-period exemption to it by reference to the equal-treatment principle in Article 23(3) of the double taxation treaty between Slovakia and Czechia. In the guideline this interpretation is tied to that specific treaty; it does not state it expressly for other treaties.
The remaining exemptions are narrow: a taxpayer operating a sheltered workshop or sheltered workplace for at least part of the tax period, a registered social enterprise, periods of liquidation and bankruptcy, and entities not established for business. According to the guideline, a resident of a state with which Slovakia has no double taxation treaty pays the minimum tax whenever it files a tax return and its tax is lower than the minimum.
What is decided on 31 December 2026 and what on 31 March 2027
A company whose tax period is the calendar year knows the decisive quantity on 31 December 2026: on that date its taxable revenue for 2026 is closed, and it sets both the rate and the minimum tax band. The tax return and payment of the tax or minimum tax follow by 31 March 2027, unless the company extends the deadline.
Taxable revenue for 2026 continues to have effect. Advance payments for 2027 are calculated from the 2026 tax base at the rate stated in the 2026 return (primary source Financial Directorate of the Slovak Republic, guideline 6/DZPaU/2026/MP on advance payments, 13. 2. 2026). A company that exceeds 5 000 000 euros of taxable revenue in 2026 will therefore, after the filing deadline for the 2026 return, pay advances derived from the 24 % rate even if its turnover falls in 2027; no advances are paid if that tax does not exceed 5 000 euros.
The guideline of 18 August 2026 states that for the 2026 tax period “a new form will be determined” for the tax return. A company with a financial year will apply the new 11 520 euro band for the first time for the 2026/2027 financial year.
Implications for the 2026 tax period
First, the corporate tax rate in Slovakia is not broken down into profit brackets. The Act selects one of three rates according to taxable revenue and applies it to the whole tax base; the Financial Directorate of the Slovak Republic example with a base of 1 250 000 euros and a tax of 300 000 euros confirms this.
Second, since 2026 the same taxable revenue also determines the minimum tax. The 5 000 000 euro threshold appears twice in the Act, and crossing it changes at once the rate from 21 to 24 % and the minimum tax from 3 840 to 11 520 euros. Above that threshold, every company with a tax base below 48 000 euros pays the minimum tax, unless it claims reliefs or falls under the exemptions in § 46b(7).
Third, the difference between the bracket reading and the Act is not academic. For a model company with taxable revenue of 1 200 000 euros and a base of 150 000 euros it amounts to 11 000 euros; for a company with 6 000 000 euros of revenue and a base of 400 000 euros, to 23 000 euros. A new company is exempt from the minimum tax only for the tax period of its creation, and from the rate rule not at all.
The question of how much profit falls into the ten-percent bracket therefore has no answer. What decides is the revenue the company achieves in the year, and that is closed before the profit is known.
Zdroje a dáta
Primary sources: Slov-lex — Act No. 595/2003 Coll. on Income Tax, version effective from 1 January 2026, compared with that from 31 December 2026; Financial Directorate of the Slovak Republic — methodological guideline on the minimum tax of a legal entity under § 46b, published 18 August 2026, and guideline 6/DZPaU/2026/MP on corporate advance payments of 13 February 2026; Financial Administration of the Slovak Republic — support database, answer “sadzba dane”.
Advisory sources: PwC Worldwide Tax Summaries, Slovak Republic, reviewed 9 September 2026, and ADVISON, guide to the taxation of an s.r.o. of 29 August 2026, used to compare terminology, not as a source of the norm. The commercial text by Arrive (7 September 2026) is quoted as evidence of the bracket reading, not as a source of figures. The table of six intervals, the threshold tax bases and the calculations for companies A to C are Symbol Consulting’s own calculation from the rates and amounts set out in the Act.
This material was reviewed by the editorial team of Symbol Consulting DMCC, an advisory firm that provides company setup and licensing, tax and regulatory compliance, and market entry consulting across multiple countries.
This text is a general analysis of the legislation in force and does not constitute legal, tax, immigration or financial advice.