Slovak Republic

Tax Guide
2012
PKF Worldwide Tax Guide 2012 I
FOREWORD
A countrys tax regime is always a key factor for any business considering moving
into new markets. What is the corporate tax rate? Are there any incentives for
overseas businesses? Are there double tax treaties in place? How will foreign source
income be taxed?
Since 1994, the PKF network of independent member rms, administered by PKF
International Limited, has produced the PKF Worldwide Tax Guide (WWTG) to provide
international businesses with the answers to these key tax questions. This handy
reference guide provides clients and professional practitioners with comprehensive
tax and business information for 100 countries throughout the world.
As you will appreciate, the production of the WWTG is a huge team effort and I
would like to thank all tax experts within PFK member rms who gave up their time
to contribute the vital information on their countrys taxes that forms the heart of this
publication. I would also like thank Richard Jones, PKF (UK) LLP, Kevin Reilly, PKF
Witt Mares, and Kaarji Vaughan, PKF Melbourne for co-ordinating and checking the
entries from countries within their regions.
The WWTG continues to expand each year reecting both the growth of the PKF
network and the strength of the tax capability offered by member rms throughout
the world.
I hope that the combination of the WWTG and assistance from your local PKF
member rm will provide you with the advice you need to make the right decisions
for your international business.
Jon Hills
PKF (UK) LLP
Chairman, PKF International Tax Committee
jon.hills@uk.pkf.com
PKF Worldwide Tax Guide 2012 II
IMPORTANT DISCLAIMER
This publication should not be regarded as offering a complete explanation of the
taxation matters that are contained within this publication.
This publication has been sold or distributed on the express terms and understanding
that the publishers and the authors are not responsible for the results of any actions
which are undertaken on the basis of the information which is contained within this
publication, nor for any error in, or omission from, this publication.
The publishers and the authors expressly disclaim all and any liability and
responsibility to any person, entity or corporation who acts or fails to act as a
consequence of any reliance upon the whole or any part of the contents of this
publication.
Accordingly no person, entity or corporation should act or rely upon any matter or
information as contained or implied within this publication without rst obtaining
advice from an appropriately qualied professional person or rm of advisors, and
ensuring that such advice specically relates to their particular circumstances.
PKF International is a network of legally independent member rms administered by
PKF International Limited (PKFI). Neither PKFI nor the member rms of the network
generally accept any responsibility or liability for the actions or inactions on the part
of any individual member rm or rms.
PKF Worldwide Tax Guide 2012 III
PREFACE
The PKF Worldwide Tax Guide 2012 (WWTG) is an annual publication that provides
an overview of the taxation and business regulation regimes of 100 of the worlds
most signicant trading countries. In compiling this publication, member rms of the
PKF network have based their summaries on information current as of 30 September
2011, while also noting imminent changes where necessary.
On a country-by-country basis, each summary addresses the major taxes applicable
to business; how taxable income is determined; sundry other related taxation
and business issues; and the countrys personal tax regime. The nal section of
each country summary sets out the Double Tax Treaty and Non-Treaty rates of tax
withholding relating to the payment of dividends, interest, royalties and other related
payments.
While the WWTG should not to be regarded as offering a complete explanation of
the taxation issues in each country, we hope readers will use the publication as their
rst point of reference and then use the services of their local PKF member rm to
provide specic information and advice.
In addition to the printed version of the WWTG, individual country taxation guides are
available in PDF format which can be downloaded from the PKF website at www.pkf.com
PKF INTERNATIONAL LIMITED
APRIL 2012
PKF INTERNATIONAL LIMITED
ALL RIGHTS RESERVED
USE APPROVED WITH ATTRIBUTION
PKF Worldwide Tax Guide 2012 IV
ABOUT PKF INTERNATIONAL LIMITED
PKF International Limited (PKFI) administers the PKF network of legally independent
member rms. There are around 300 member rms and correspondents in 440
locations in around 125 countries providing accounting and business advisory services.
PKFI member rms employ around 2,200 partners and more than 21,400 staff.
PKFI is the 10th largest global accountancy network and its member rms have $2.6
billion aggregate fee income (year end June 2011). The network is a member of the
Forum of Firms, an organisation dedicated to consistent and high quality standards of
nancial reporting and auditing practices worldwide.
Services provided by member rms include:
Assurance & Advisory
Corporate Finance
Financial Planning
Forensic Accounting
Hotel Consultancy
Insolvency Corporate & Personal
IT Consultancy
Management Consultancy
Taxation
PKF member rms are organised into ve geographical regions covering Africa; Latin
America; Asia Pacic; Europe, the Middle East & India (EMEI); and North America &
the Caribbean. Each region elects representatives to the board of PKF International
Limited which administers the network. While the member rms remain separate
and independent, international tax, corporate nance, professional standards, audit,
hotel consultancy, insolvency and business development committees work together to
improve quality standards, develop initiatives and share knowledge and best practice
cross the network.
Please visit www.pkf.com for more information.
PKF Worldwide Tax Guide 2012 V
STRUCTURE OF COUNTRY DESCRIPTIONS
A. TAXES PAYABLE
FEDERAL TAXES AND LEVIES
COMPANY TAX
CAPITAL GAINS TAX
BRANCH PROFITS TAX
SALES TAX/VALUE ADDED TAX
FRINGE BENEFITS TAX
LOCAL TAXES
OTHER TAXES
B. DETERMINATION OF TAXABLE INCOME
CAPITAL ALLOWANCES
DEPRECIATION
STOCK/INVENTORY
CAPITAL GAINS AND LOSSES
DIVIDENDS
INTEREST DEDUCTIONS
LOSSES
FOREIGN SOURCED INCOME
INCENTIVES
C. FOREIGN TAX RELIEF
D. CORPORATE GROUPS
E. RELATED PARTY TRANSACTIONS
F. WITHHOLDING TAX
G. EXCHANGE CONTROL
H. PERSONAL TAX
I. TREATY AND NON-TREATY WITHHOLDING TAX RATES
PKF Worldwide Tax Guide 2012 VI
A
Algeria . . . . . . . . . . . . . . . . . . . . 1 pm
Angola . . . . . . . . . . . . . . . . . . . . 1 pm
Argentina . . . . . . . . . . . . . . . . . . 9 am
Australia -
Melbourne . . . . . . . . . . . . . 10 pm
Sydney . . . . . . . . . . . . . . . 10 pm
Adelaide . . . . . . . . . . . . 9.30 pm
Perth . . . . . . . . . . . . . . . . . . 8 pm
Austria . . . . . . . . . . . . . . . . . . . . 1 pm
B
Bahamas . . . . . . . . . . . . . . . . . . . 7 am
Bahrain . . . . . . . . . . . . . . . . . . . . 3 pm
Belgium . . . . . . . . . . . . . . . . . . . . 1 pm
Belize . . . . . . . . . . . . . . . . . . . . . 6 am
Bermuda . . . . . . . . . . . . . . . . . . . 8 am
Brazil. . . . . . . . . . . . . . . . . . . . . . 7 am
British Virgin Islands . . . . . . . . . . . 8 am
C
Canada -
Toronto . . . . . . . . . . . . . . . . 7 am
Winnipeg . . . . . . . . . . . . . . . 6 am
Calgary . . . . . . . . . . . . . . . . 5 am
Vancouver . . . . . . . . . . . . . . 4 am
Cayman Islands . . . . . . . . . . . . . . 7 am
Chile . . . . . . . . . . . . . . . . . . . . . . 8 am
China - Beijing . . . . . . . . . . . . . . 10 pm
Colombia . . . . . . . . . . . . . . . . . . . 7 am
Croatia . . . . . . . . . . . . . . . . . . . . 1 pm
Cyprus . . . . . . . . . . . . . . . . . . . . 2 pm
Czech Republic . . . . . . . . . . . . . . 1 pm
D
Denmark . . . . . . . . . . . . . . . . . . . 1 pm
Dominican Republic . . . . . . . . . . . 7 am
E
Ecuador . . . . . . . . . . . . . . . . . . . . 7 am
Egypt . . . . . . . . . . . . . . . . . . . . . 2 pm
El Salvador . . . . . . . . . . . . . . . . . 6 am
Estonia . . . . . . . . . . . . . . . . . . . . 2 pm
F
Fiji . . . . . . . . . . . . . . . . .12 midnight
Finland . . . . . . . . . . . . . . . . . . . . 2 pm
France. . . . . . . . . . . . . . . . . . . . . 1 pm
G
Gambia (The) . . . . . . . . . . . . . 12 noon
Georgia . . . . . . . . . . . . . . . . . . . . 3 pm
Germany . . . . . . . . . . . . . . . . . . . 1 pm
Ghana . . . . . . . . . . . . . . . . . . 12 noon
Greece . . . . . . . . . . . . . . . . . . . . 2 pm
Grenada . . . . . . . . . . . . . . . . . . . 8 am
Guatemala . . . . . . . . . . . . . . . . . . 6 am
Guernsey . . . . . . . . . . . . . . . . 12 noon
Guyana . . . . . . . . . . . . . . . . . . . . 7 am
H
Hong Kong . . . . . . . . . . . . . . . . . 8 pm
Hungary . . . . . . . . . . . . . . . . . . . 1 pm
I
India . . . . . . . . . . . . . . . . . . . 5.30 pm
Indonesia. . . . . . . . . . . . . . . . . . . 7 pm
Ireland . . . . . . . . . . . . . . . . . . 12 noon
Isle of Man . . . . . . . . . . . . . . 12 noon
Israel . . . . . . . . . . . . . . . . . . . . . . 2 pm
Italy . . . . . . . . . . . . . . . . . . . . . . 1 pm
J
Jamaica . . . . . . . . . . . . . . . . . . . 7 am
Japan . . . . . . . . . . . . . . . . . . . . . 9 pm
Jersey . . . . . . . . . . . . . . . . . . 12 noon
Jordan . . . . . . . . . . . . . . . . . . . . 2 pm
K
Kazakhstan . . . . . . . . . . . . . . . . . 5 pm
Kenya . . . . . . . . . . . . . . . . . . . . . 3 pm
Korea . . . . . . . . . . . . . . . . . . . . . 9 pm
Kuwait . . . . . . . . . . . . . . . . . . . . . 3 pm
L
Latvia . . . . . . . . . . . . . . . . . . . . . 2 pm
Lebanon . . . . . . . . . . . . . . . . . . . 2 pm
Liberia . . . . . . . . . . . . . . . . . . 12 noon
Luxembourg . . . . . . . . . . . . . . . . 1 pm
M
Malaysia . . . . . . . . . . . . . . . . . . . 8 pm
Malta . . . . . . . . . . . . . . . . . . . . . 1 pm
Mauritius . . . . . . . . . . . . . . . . . . . 4 pm
Mexico . . . . . . . . . . . . . . . . . . . . 6 am
Morocco . . . . . . . . . . . . . . . . 12 noon
N
Namibia. . . . . . . . . . . . . . . . . . . . 2 pm
Netherlands (The) . . . . . . . . . . . . . 1 pm
New Zealand . . . . . . . . . . .12 midnight
Nigeria . . . . . . . . . . . . . . . . . . . . 1 pm
Norway . . . . . . . . . . . . . . . . . . . . 1 pm
O
Oman . . . . . . . . . . . . . . . . . . . . . 4 pm
P
Panama. . . . . . . . . . . . . . . . . . . . 7 am
Papua New Guinea. . . . . . . . . . . 10 pm
Peru . . . . . . . . . . . . . . . . . . . . . . 7 am
Philippines . . . . . . . . . . . . . . . . . . 8 pm
Poland. . . . . . . . . . . . . . . . . . . . . 1 pm
Portugal . . . . . . . . . . . . . . . . . . . 1 pm
Puerto Rico . . . . . . . . . . . . . . . . . 8 am
INTERNATIONAL TIME ZONES
AT 12 NOON, GREENWICH MEAN TIME, THE STANDARD TIME
ELSEWHERE IS:
PKF Worldwide Tax Guide 2012 VII
Q
Qatar. . . . . . . . . . . . . . . . . . . . . . 8 am
R
Romania . . . . . . . . . . . . . . . . . . . 2 pm
Russia -
Moscow . . . . . . . . . . . . . . . 3 pm
St Petersburg . . . . . . . . . . . . 3 pm
S
Sierra Leone . . . . . . . . . . . . . 12 noon
Singapore . . . . . . . . . . . . . . . . . . 7 pm
Slovak Republic . . . . . . . . . . . . . . 1 pm
Slovenia . . . . . . . . . . . . . . . . . . . 1 pm
South Africa . . . . . . . . . . . . . . . . . 2 pm
Spain . . . . . . . . . . . . . . . . . . . . . 1 pm
Sweden . . . . . . . . . . . . . . . . . . . . 1 pm
Switzerland . . . . . . . . . . . . . . . . . 1 pm
T
Taiwan . . . . . . . . . . . . . . . . . . . . 8 pm
Thailand . . . . . . . . . . . . . . . . . . . 8 pm
Tunisia . . . . . . . . . . . . . . . . . 12 noon
Turkey . . . . . . . . . . . . . . . . . . . . . 2 pm
Turks and Caicos Islands . . . . . . . 7 am
U
Uganda . . . . . . . . . . . . . . . . . . . . 3 pm
Ukraine . . . . . . . . . . . . . . . . . . . . 2 pm
United Arab Emirates . . . . . . . . . . 4 pm
United Kingdom . . . . . . .(GMT) 12 noon
United States of America -
New York City . . . . . . . . . . . . 7 am
Washington, D.C. . . . . . . . . . 7 am
Chicago . . . . . . . . . . . . . . . . 6 am
Houston . . . . . . . . . . . . . . . . 6 am
Denver . . . . . . . . . . . . . . . . 5 am
Los Angeles . . . . . . . . . . . . . 4 am
San Francisco . . . . . . . . . . . 4 am
Uruguay . . . . . . . . . . . . . . . . . . . 9 am
V
Venezuela . . . . . . . . . . . . . . . . . . 8 am
Vietnam . . . . . . . . . . . . . . . . . . . . 7 pm
PKF Worldwide Tax Guide 2012 1
Slovak Republic
SLOVAK REPUBLIC
Currency: Euro Dial Code To: 421 Dial Code Out: 00
(EUR)
Member Firm:
City: Name: Contact Information:
Prievidza Richard Clayton Budd 46 518 38 29
budd@hzpkf.sk
A. TAXES PAYABLE
COMPANY TAX
Slovak resident companies are subject to corporate income tax on income derived
from worldwide sources, while non-residents are subject to corporate income tax only
on income sourced in the Slovak Republic. Since 1 January 2004 the Income Tax Act
(No. 595/2003 Coll.) has, in effect, brought signicant reforms favouring taxpayers.
Resident companies are those which have their legal seat or place of effective
management in the Slovak Republic.
The company tax rate is 19% which is the at rate for all persons paying tax without
exception. The scal year is the calendar year or the business year of the taxpayer
(subject to notication to the tax authorities). Tax is due and payable in a single
payment if the previous tax liability was less than 1,659.70; in quarterly instalments
if the previous tax liability was between 1,659.70 and 16,596.96); and in monthly
instalments if the previous tax liability was over 16,596.96). Tax returns for the
applicable period should be led by 31 March of the following year, although a person
may ask for a three-month extension in the case of income from inside Slovakia and
a six-month extension in the case of income from outside Slovakia.
A taxpayer may, of their own accord, postpone the ling of a tax return for up to three
months. If a part of the taxed income is also from sources from outside the Slovak
Republic, the taxpayer may postpone ling a tax return for up to six months. Taxpayers
can donate 1.5 -2% of their paid taxes to non-prot organisations. Based on a written
request, the tax authorities will provide the donated amount to the designated non-prot
organisation. There is an opportunity to inform the tax authorities in writing about any
change of the tax period from the calendar year to a scal year.
CAPITAL GAINS TAX
There is no separate capital gains tax. Gains from sales of assets are incorporated
into taxable income when determining the companys tax liability.
BRANCH PROFITS TAX
There is no separate branch prots tax in the Slovak Republic. The income of Slovak
branches of foreign companies is subject to taxation in the Slovak Republic at the at
rate of 19%.
SALES TAX/VALUE ADDED TAX (VAT)
The current VAT Act (No. 222/2004 Coll.) entered into effect with the accession of the
Slovak Republic into the European Union on 1 May 2004. The Act is harmonized with
similar laws in other EU Member States (based on Council Directive 2006/112/EC).
VAT is paid on the supply of goods and services within the country, the intra-Community
acquisition of goods, and on the importation of goods from countries outside the EU.
The standard rate was 19% but has been temporarily raised to 20% from 1 January
2010. There is a reduced rate of 10% for medicines, books and other printed
matter. There is also a special excise tax imposed on selected commodities such as
petroleum, wine, spirits, tobacco, beer, electricity, coal and natural gas.
FRINGE BENEFITS TAX
Fringe benets (goods or services) to employees are taxed as part of their total taxable
amount at a at rate of 19%. Any tax levied on an employee is deducted by the employer.
LOCAL TAXES
The main local taxes that a municipality can levy are property tax (on land, buildings and ats),
hotel tax, tax on the operation of vending machines and machines that do not offer cash
prizes, as well as local fees on community waste disposal and low-value construction waste.
Self-governing regional authorities may also levy taxes on M, N and O category motor
vehicles used for business purposes or for activities where the income derived is
subject to income tax. Local taxes paid are a recognised deduction from income tax.
PKF Worldwide Tax Guide 2012 2
OTHER TAXES
An annual tax is levied on the owner or benecial owner of a building situated within
the Slovak Republic. The rate of tax depends on the size, quality, type and location of
the property. This tax is deductible on a cash basis for income tax purposes.
There is no inheritance tax, gift tax or real estate transfer tax levied in the Slovak Republic.
Employers pay contributions to social security and health insurance amounting to 35.2%
of gross payroll shown on the pay slip up to a maximum assessment cap set by law. This
tax is deductible when determining taxable income.
The rates are as follows:
Health insurance and hospitalisation 11.4%
Retirement insurance 14.0%
Disability 3.0%
Unemployment 1.0%
Accident insurance 0.8%
Others 5.0%
B. DETERMINATION OF TAXABLE INCOME
A companys taxable income is determined by ascertaining assessable income according
to ofcial accounting and then subtracting all deductions. Generally, to be deductible,
expenditure must be wholly and exclusively incurred for the purposes of the business.
Certain income that has already been subject to withholding tax is not included in
taxable income, with some exceptions (i.e. royalties). Special additional conditions apply
to deductions of some expenses. For example, special expenses dened by tax law are
tax-deductible only for the period in which they are fully paid and special income (e.g.
contractual penalties, late fees) is taxable only for the period in which it is received.
DEPRECIATION
The tax law prescribes the rules under which a business depreciates its assets.
Property, plant and equipment are divided into four groups according to their
expected useful life (periods ranging from four to 20 years). A taxpayer may choose
either straight-line or accelerated (declining-balance) depreciation. The choice of
method is carried out on an asset-by-asset basis and, once the method is selected,
it cannot be changed. Intangible assets (capitalised development costs) can be
amortised over ve years from when they were expensed. Amortisation may be
postponed without the taxpayer losing the right to amortise in future periods.
Note: Starting from 1 January 2012, assets are depreciated in the rst year pro rata
according to the number of months for which the asset was owned during the year.
STOCK/INVENTORY
All trading stock on hand is valued at purchase price including any additional
procurement costs incurred. Internally generated inventory must be valued on the
basis of production costs. In the event that a temporary impairment in inventories is
found during stocktaking, an allowance is made. Accepted valuation methods include
FIFO, average acquisition costs or pre-dened (planned) prices, but not LIFO.
CAPITAL GAINS AND LOSSES
Capital gains are considered taxable income and taxed at the 19% tax rate. Losses
from the sale of stock or a share of a limited liability company are recognised as a tax
deduction only up to the amount of income. There are three exceptions when the loss
is fully recognised for tax purposes: a loss from the sale of specially quoted stock on
an exchange; a loss from the sale of bonds to the extent of income received from the
bond included in its price; and a loss from the sale of stock certied by a broker.
DIVIDENDS
In the Slovak Republic, dividends are subject to neither personal nor corporate
income tax. This applies to dividends paid out in 2004 onwards.
For prots earned and not paid out as dividends prior to 2004, the undistributed
prots are taxed at a rate of 19% when they are paid out or at the tax rate according
to the applicable double taxation treaty. Dividends paid out by companies in a group
to corporate shareholders resident in an EU Member State who have a direct holding
of at least 25% of the capital is not taxed.
Note: all taxable income and dividends, starting in 2011, will be included in
assessments for liability to health insurance contributions.
Slovak Republic
PKF Worldwide Tax Guide 2012 3
INTEREST DEDUCTION
Interest paid by a company is treated as an ordinary business expense.
The Slovak Republic is not planning any thin-capitalisation related restrictions on
deducting interest from loans.
LOSSES
Losses in a year may be carried forward and set off against prots in the subsequent
seven years without requiring the losses deducted to be reinvested. The losses may
be set off non-uniformly over the ve-year period.
FOREIGN SOURCED INCOME
The Slovak authorities levy taxes on all foreign income received by Slovak residents
and companies whose registered ofce is in the Slovak Republic..
INCENTIVES
Incentives for investors are governed by legislation on government subsidies (No.
231/1999 Coll., as amended), under which tax benets may also be an incentive to
invest. Specic tax benets have to be negotiated with the Economics Ministry.
C. FOREIGN TAX RELIEF
Tax paid in a foreign country is set off against tax liabilities in the home country in
accordance with double taxation treaties with the applicable country (either by a deduction
or exemption).
Income earned by individuals (i.e. from wages and salaries) is exempt from taxation where
proof is given that the income will be taxed abroad and where the Slovak Republic has
no double taxation treaty with the other country which has taxed the income. If a double
taxation treaty exists, the treaty method of exemption takes precedence.
D. CORPORATE GROUPS
There is no concept of corporate groups in the Slovak Republic. For tax purposes,
prots and losses of holding and subsidiary companies may not be consolidated.
E. RELATED PARTY TRANSACTIONS
All transactions between related companies realised across borders must be conducted
at an arms length basis with the meaning of arms length price depending upon each
individual transaction. Any difference arising between the price of the actual transaction
and that regarded as the arms length price will be adjusted for tax purposes.
F. WITHHOLDING TAX
As the at tax rate of 19% is generally applied within the Slovak Republic, this rate also
applies to withholding taxes on interest and royalties. This tax rate may be reduced to the
tax rate set in the relevant double taxation treaty. There is no withholding tax on dividends.
G. EXCHANGE CONTROL
Slovakia has been using the Euro as its currency since 1 January 2009. The Foreign
Exchange Act allows the Euro to be used freely to pay for business and other costs,
for direct investment and reinvestment and for purchase of real estate property
abroad. Also, it is legal to accept nancial credit (i.e. receive loans) from companies
with no registered ofce within the Slovak Republic but, in certain circumstances,
there is a requirement to report such credit.
The Foreign Exchange Act partially restricts the ability for companies without a
registered ofce in the Slovak Republic to acquire real property in the Slovak
Republic. Capital transfers are regulated and there is a duty to report and obtain a
special permit or licence from the central bank.
H. PERSONAL TAX
Personal income tax is payable by permanent residents within the Slovak Republic
individually on their worldwide income. Non-residents are only subject to tax on Slovak-
sourced income. If an individual spends 183 days or more of the relevant calendar year
in the Slovak Republic, that person is deemed to be resident in the Slovak Republic.
Under Slovak law, employees hired under an employment contract pay contributions for
social security, retirement and health insurance amounting to 13.4%. This is withheld
by the employer.
Slovak Republic
PKF Worldwide Tax Guide 2012 4
The rate of contributions is as follows:
Health insurance and hospitalisation 5.4%
Retirement 4.0%
Disability 3.0%
Unemployment 1.0%
Different rates apply to contributions made by self-employed persons. The at tax
rate of 19% in the Slovak Republic also applies to personal taxes. The personal
allowance is reduced on a sliding scale to zero when taxable income is more than
176 times the subsistence wage (in 2011 this was 33,427.68).
Tax returns for the applicable period should be led by 31 March of the following year,
although a person may ask for a three-month extension in the case of income from inside
Slovakia and a six-month extension in the case of income from outside Slovakia. Provisional
tax payments on income from employment are made monthly. Provisional payments
on income from business operations, rental income, etc, are paid quarterly or monthly
depending on the last known tax liability (between 1,659.70 and 16,596.96)/over
16,596.96 and as a single payment if the last tax liability did not exceed 1,659.70).
Individuals can request the tax authorities to donate 2% of their Slovak personal
income tax liability to an eligible Slovak non-prot organisation. The Act sets out who
can receive such charitable contributions, for example, civic associations, foundations
and religious organisations. These recipients must meet several conditions. Real
property tax is paid on land and buildings, with the tax rate depending on the quality
of land and location of the buildings (number of citizens).
I. TREATY AND NON-TREATY WITHHOLDING TAX RATES
Dividends
(%)
(1) Interest
(%)
(2)
(3)
(5)
Royalties
(%)
(2)
(4)
Non-Treaty Countries: 0 19 19
Treaty Countries:
Australia 0 10 10
Austria 0 0 5/0
Belarus 0 10/0 10/5
Belgium 0 10/0 5/0
Bosnia and Herzegovina 0 0 10
Brazil 0 15/10 15/25
Bulgaria 0 10 10
Canada 0 10/0 10/0
China 0 10/0 10
Croatia 0 10 10
Cyprus 0 10/0 5/0
Czech Republic 0 0 10/0
Denmark 0 0 5/0
Estonia 0 10/0 10
Finland 0 0 10/5/1
France 0 0 5/0
Germany 0 0 5
Greece 0 10 10/0
Hungary 0 0 10
Iceland 0 0 10
India 0 15/0 30
Indonesia 0 10/0 15/10
Ireland 0 0 10/0
Israel 0 10/5/2 (5) 5
Slovak Republic
PKF Worldwide Tax Guide 2012 5
Dividends
(%)
(1) Interest
(%)
(2)
(3)
(5)
Royalties
(%)
(2)
(4)
Italy 0 0 5/0
Japan 0 10/0 10/0
Kazakhstan 0 10/0 10
Korea 0 0/10 10/0
Latvia 0 10/0 10
Lithuania 0 10 10
Libya 0 10 5
Luxembourg 0 0 10/0
Macedonia 0 10 10
Malta 0 0 5
Mexico 0 10/0 10
Moldova 0 10 10
Montenegro 0 10 10
Netherlands 0 0 5
Nigeria 0 15 15
Norway 0 0 5/0
Poland 0 10/0 5
Portugal 0 10 10
Romania 0 10/0 10/15
Russia 0 0 10
Serbia 0 10 10
Singapore 0 0 10
Slovenia 0 10 10
South Africa 0 0 10
Spain 0 0 5/0
Sri Lanka 0 10/0 10/0
Sweden 0 0 5/0
Switzerland 0 10 10/0
Syria 0 10 12
Taiwan 0 0/10 5/10
Tunisia 0 12 15/5
Turkey 0 10/0 10
Turkmenistan 0 10/0 10
Ukraine 0 10 10
United Kingdom 0 0 10/0
United States 0 0 10/0
Uzbekistan 0 10 10
Vietnam 0 10 5/10/15
1 Dividends paid out within the Slovak Republic are generally not subject to tax
where paid out of prots generated from 1 January 2004 onwards.
2 Interest and royalties are tax exempt for associated companies in EU Member
States in accordance with EU Directives (see Section F above).
3 The lower tax rate generally applies to interest on loans provided by the
government or the central bank. It is advisable to check the applicable double
taxation treaty for specic details.
4 Separate tax rates for royalties are generally applied so that the higher rate is
for industrial royalties and the lower rate is for cultural royalties. It is advisable
to check the applicable double taxation treaty for specic details.
5 The withholding rate is reduced to 5% if a bank or nancial institution receives
the interest.
Slovak Republic
PKF Worldwide Tax Guide 2012 565
www.pkf.com $100