When computing the tax base for the year 2024 it is necessary to consider a new interest cost limitation rule in line with Art. 17k of the Slovak Income Tax Act (“SITA”) which is applied in preference to the still valid thin capitalization rules (Art. 21a SITA).

The return to sustainable public finances and the stabilization of public debt in relation to GDP is a priority of the Slovak government defined in the National reform program of the Slovak Republic for 2024. In this program, the Government of the Slovak Republic provides an overview of already implemented and planned measures based on specific recommendations of the Council of the European Union for the Slovak Republic, such as more effective tax collection using the potential of environmental and property taxes. The interdepartmental comment procedure ended on April 8, 2024 and comments are currently being evaluated. The proposal mentions the following measures related to the tax area.

The government of the Slovak Republic has approved and filed to the Slovak Parliament for further proceeding the so-called “lex consolidation” representing a set of measures amending the particular acts. Please note that these changes have not yet been approved by the Slovak Parliament, they represent only the proposed measures and during the process of negotiation may be subject to further changes.

V súvislosti s blížiacim sa koncom roka 2023 by sme Vás chceli upozorniť, že od 1. januára 2024 vstupuje do platnosti ustanovenie § 17k zákona o dani z príjmov („ZDP“), týkajúce sa obmedzenia daňovej uznateľnosti úrokových nákladov.