Amending Act 272/2025 Coll. removed the natural person – entrepreneur from Slovakia’s Act on the financial transaction tax. It did not remove the legal entity. For a foreign manufacturer entering the Slovak market through an s. r. o., through a branch, or with no entity at all, the transaction tax was not abolished on 1 January 2026 — on the contrary, the Act set out more precisely from when and under what circumstances it binds that manufacturer.
This text reconstructs the personal scope of the tax from the Act in force and from the form issued for it by the Financial Directorate of the Slovak Republic: who is a taxpayer, from which day, what is filed and within what deadline. It does not calculate the tax burden of any particular company, does not assess individual payment flows, and does not judge whether the tax is well or badly designed.
“Was the transaction tax abolished?” is the wrong question
The abolition concerned one category of taxpayers, not the tax. Act 272/2025 Coll., approved on 30 September 2025 and promulgated on 21 October 2025, took effect on 1 January 2026 and removed the natural person – entrepreneur from Act 279/2024 Coll. (primary source Slov-lex, promulgated text of 21. 10. 2025). The rates, the subject matter of the tax and the monthly periodicity did not change.
The question that decides a market entry reads differently: from which day does a foreign company become a taxpayer within the meaning of the Act. The answer does not depend on whether the company has an entity registered in Slovakia, but on two facts — where the provider of its payment services is seated, and whether its activity in Slovakia meets the definition of a permanent establishment.
The difference between the two questions is practical. The first leads to the conclusion that the administrative burden fell in 2026, which is true for more than four hundred thousand Slovak sole traders. The second leads to a map of payment flows in which a foreign investor usually finds at least one item that was previously not treated as subject to the tax — a cost recharged by the parent company.
Who is a taxpayer under Section 3(1) of Act 279/2024 Coll.
A taxpayer is a legal entity that carries out financial transactions and is a user of the payment services of a provider, or a legal entity on whose behalf financial transactions are carried out. The Act then divides it into a taxpayer with unlimited tax liability — a legal entity seated in Slovakia — and a taxpayer with limited tax liability, which has no seat in Slovakia (primary source Slov-lex, text in force from 1. 1. 2026).
| Category | Provision | Who falls into it | What triggers it |
|---|---|---|---|
| Unlimited tax liability | Section 3(1)(a) | Legal entity seated in the Slovak Republic | The seat in Slovakia itself |
| Limited tax liability — account | Section 3(1)(b), first point | Legal entity with no seat in Slovakia | It is a user of the payment services of a provider seated in Slovakia |
| Limited tax liability — establishment | Section 3(1)(b), second point | Legal entity with no seat in Slovakia | It carries out activity in Slovakia through a permanent establishment |
| Not a taxpayer | Section 3(2) | Municipalities, self-governing regions, budgetary and contributory organisations, civic associations, foundations, schools in the state network and other exhaustively listed entities | The status of the entity; notified to the tax payer under Section 12(6) |
For a market entry, the second and third rows are decisive. A foreign company can become a taxpayer without registering anything in the Slovak commercial register — it is enough that it opens an account with a bank seated in Slovakia, or that its activity meets the definition of a permanent establishment. The Financial Administration of the Slovak Republic phrases it the same way in its published answer: what matters is the seat of the payment services provider, or the establishment, not the registration of the company (primary source Financial Administration of the Slovak Republic, page as at 22. 8. 2026).
The rate under Section 6 of the Act is 0,4 % of the tax base, up to a maximum of 40 euros per financial transaction; 0,8 % on cash withdrawals with no cap, and 2 euros per payment card, the tax period for a card being the calendar year under § 9(2). The cap of 40 euros means the tax is regressive: on large payments its effective rate falls, while on a dense flow of smaller payments the full 0,4 % remains. It is the second profile that is typical of supply chains running on JIT.
Which of the two categories applies decides the scope of the tax more than the rate does. Under Section 4(1)(a) of the Act, the subject of the tax is the debiting of an amount from the payment account of a taxpayer with unlimited tax liability held in Slovakia or abroad, whereas for a taxpayer with limited tax liability it is only an account held in Slovakia, or an account where the transaction relates to the activity of a permanent establishment.
The asymmetry has a direct consequence for the choice of entry structure. A Slovak s. r. o. with a foreign owner is a taxpayer with unlimited liability, and the tax therefore also reaches its payments from an account held in another country — moving payment traffic outside Slovakia does not narrow the scope of the tax. A foreign company with no Slovak seat is in the opposite position: outside an establishment and outside a domestic account, no subject of the tax arises.
The Act at the same time excludes a whole range of payments from the subject of the tax. Under Section 4(2)(a), it does not cover payment operations carried out in connection with the payment of taxes, levies, fees and contributions that are revenue of the state budget, customs debt, contributions to the Social Insurance Agency and health insurance contributions. Payroll and contribution flows therefore do not form the tax base; the base is formed by payments to suppliers, intra-group payments and cash withdrawals.
Permanent establishment and the fifteen-day threshold
A permanent establishment is, under Section 2(2) of the Act, a fixed place or facility for carrying out activity through which a taxpayer with limited tax liability carries out its activity in Slovakia — in particular the place from which the activity is organised, a branch, an office, a workshop, a workplace, a point of sale or a technical facility. A place is treated as fixed if it is used continuously or repeatedly.
For one-off activity the Act sets a quantitative threshold: a place is treated as fixed if the duration of the activity exceeds 15 days during the tax period. Since the tax period under Section 9(1) is the calendar month, this means fifteen days in a month, not in a year. The same fifteen-day threshold applies separately to a building site and to the place where construction and assembly projects are carried out, and separately to the provision of services by the taxpayer or by persons working for it.
The Act adds further situations that count as a permanent establishment regardless of the number of days: the provision of an information society service that constitutes the sale or the brokering of a sale through an electronic interface located in Slovakia; a dependent agent who continuously or repeatedly negotiates or concludes contracts on behalf of the taxpayer; and insurance risk located in Slovakia. The reading of the fifteen-day threshold published by KPMG Slovensko is consistent with the text of the Act (consulting source KPMG Slovensko, 27. 11. 2025).
The practical consequence for a nearshoring project is plain. An assembly team sent to an automotive anchor for three weeks within a single calendar month exceeds fifteen days, even where the work is a one-off contract and the parent company has not even registered a branch in Slovakia. The test is applied month by month.
Recharged costs and the monthly tax period
A recharged cost is the amount of a financial transaction carried out on behalf of the taxpayer by a person other than the taxpayer; for a taxpayer with limited tax liability that transaction must relate to its activity in Slovakia. The rate is the same — 0,4 % of the tax base. In this case the tax payer under Section 3(3)(d) is the taxpayer to whom the cost is recharged, not the bank.
For recharged costs the tax period is the calendar month in which the taxpayer settled them, and set-off of receivables also counts as settlement. For intra-group relationships this matters more than the rate itself: setting off mutual receivables between a subsidiary and a parent starts a tax period in the same way as a bank transfer.
The deadline follows from Section 10(1) of the Act. The tax payer calculates the tax, collects it and remits it to the tax administrator no later than the end of the calendar month immediately following the tax period; within the same deadline it files an electronic notification of the amount of tax. The Financial Directorate of the Slovak Republic set a new form for this notification, OZNDFTv26-1, first used for the tax period January 2026, while the previous form OZNDFTv25-1 remained in use for periods ending 31 December 2025 (primary source Financial Directorate of the Slovak Republic, information on the OZNDFTv26-1 form, October 2025).
The same document also shows the extent of the technical change: the form dropped the birth number, the date of birth, the identification details of a natural person and the heir field. The form therefore no longer contemplates a natural person being a taxpayer.
For recharging, the tax base is defined in Section 5(2) of the Act in two ways: either as the amount of recharged costs connected with a financial transaction relating to the taxpayer’s activity in Slovakia, or as the amount of the financial transaction itself, carried out by another person and recharged to the taxpayer, if the taxpayer can evidence it. Evidence is therefore a condition of the narrower base, not a formality.
Where a transaction account is held in a currency other than the euro, the amount is converted under Section 5(3) of the Act at the reference exchange rate of the European Central Bank or the National Bank of Slovakia valid on the day the financial transaction is carried out. For groups that run their Slovak entity on an account in another currency, this means the rate on the transaction date, not a monthly average and not the rate on the date of recharging.
The transaction tax in the state budget balance to 30 June 2026
The Ministry of Finance of the Slovak Republic reports a year-on-year increase of 205,4 million euros in the financial transaction tax by 30 June 2026. State budget tax revenue reached 10 900 327 thousand euros, or 47,5 % of the approved budget, and the cash deficit was 2 969,1 million euros (primary source Ministry of Finance of the Slovak Republic, balance to 30. 6. 2026, updated 1. 7. 2026).
That figure cannot be read as a rate of growth in payment activity, and this publication does not read it that way. Under Section 13(2) of the Act the first tax period was only April 2025, and Section 13(3) allowed the tax for the first three tax periods to be remitted as late as 31 July 2025. The first half of 2025 therefore contains only a fraction of the cash yield that substantively belongs to it, while the first half of 2026 contains six full months. The year-on-year comparison here compares a ramp-up with a settled state.
The press release does not state the absolute amount collected in the first half of 2026 — it contains only the year-on-year change, and no other public document carrying that item for the same period could be found. Nor could the number of legal entities that actually remitted the tax be traced; this text therefore makes no claim about the size of the population of payers.
One reliable conclusion follows for the investment case: the tax is established in the system, its yield is rising, and as at 21 July 2026 no proposal had been tabled that would abolish it for legal entities. Three-year planning of payment costs has to account for it, and from the first month of operations rather than from the first closed accounting period.
What to verify before registering a Slovak entity
The following six items derive from the provisions of Act 279/2024 Coll. cited above and take the form of verifiable questions, not recommendations. Each of them can be answered from documents a company already holds before signing its first contract in Slovakia: the payment services agreement, the work schedule and the list of intra-group costs. The order matches the order in which these facts arise during a market entry.
- The seat of the payment services provider — is the account held with a provider seated in Slovakia, or with a provider outside Slovakia? Under Section 3(3) of the Act this fact determines whether the tax payer is the bank or the company itself.
- The number of days of activity in Slovakia for each calendar month separately, counted separately for building sites and assembly projects and separately for the provision of services — the threshold under Section 2(2) of the Act is fifteen days in a tax period.
- The list of costs paid on behalf of the Slovak entity by a parent or sister company, including those settled by set-off of receivables — under Section 9(3) of the Act, a set-off also starts a tax period.
- The electronic interface through which the sale or the brokering of a sale is carried out — is it located in Slovakia? This situation creates a permanent establishment regardless of the number of days.
- The persons who negotiate or conclude contracts in Slovakia on behalf of the foreign company — do they act on its instructions, and does it bear the business risk for them? These are the marks of a dependent agent under Section 2(2) of the Act.
- The filing calendar: the notification on form OZNDFTv26-1 is filed electronically by the end of the month following the tax period, that is twelve times a year, not once per accounting period.
Zdroje a dáta
Primary sources: Slov-lex — Act 279/2024 Coll. on the financial transaction tax in the text in force from 1 January 2026, and Act 272/2025 Coll. promulgated on 21 October 2025; Financial Directorate of the Slovak Republic — information setting the OZNDFTv26-1 form, October 2025; Financial Administration of the Slovak Republic — published answers on the tax; Ministry of Finance of the Slovak Republic — State Budget Balance to 30. 6. 2026, updated 1. 7. 2026.
Consulting source: KPMG Slovensko, commentary on the amendment of 27 November 2025, used to verify interpretative practice on the fifteen-day threshold, not as a source of the rule. All amounts are stated in euro as given in the cited documents; no currency conversions were performed in this text.
This text is a general analysis of legislation in force and does not constitute legal, tax, immigration or financial advice.