The Slovak Parliament has approved amendments to the Slovak Income Tax Act. 1 The amendments will enter into force on 1 January 2024, concerning taxation of individuals, and include changes to the tax treatment of virtual currency, sales of unlisted securities, and sales of shares in limited liability companies, amongst others. Employee’s shares schemes were regulated differently for listed shares and unlisted shares.
The amendments introduce tax relief for taxpayers investing in certain investment vehicles. This should be welcome news to such taxpayers, who may benefit from a lower tax burden. Employers of globally-mobile employees may wish to determine how their global-mobility compensation and tax policies may need adjusting in light of these changes.
1. the company has not paid any profit share (dividends) so far; and
2. these employee shares have not been/are not listed on a regulated market until the end of the tax year in which the benefit was acquired by the employee.
Another important change is that the controlled foreign companies rules ("CFC") applicable for individuals are removed, effective 1 August 2023. If there was a payment of this tax 2 before its abolition, the payment should be treated as a tax over-payment. For legal entities, the CFC rules remain in force.
The rules concerning taxation of various investments – whether those investments be in securities, LLCs, or virtual currency – can be complex and compliance can be tricky, even more so when dealing with globally-mobile employees who may be subject to the new rules. An important change is also the different tax point for employees’ share schemes in case of listed employee shares compared to unlisted employee shares where the dividends have not been paid so far.
In preparation for 1 January 2024, when these changes take effect, employers and their employees may have questions about how the changes apply to them and what steps they might take in order to benefit from the tax relief described in this newsletter. It is recommended they consult with their qualified professional tax adviser or a member of the GMS / People Services team in Slovakia (see the Contacts section) before taking any decisions.
1 Slovak Income Tax Act. no 595/2003 Coll.
2 Income tax related to CFC rules (from companies in low tax jurisdictions). This may be an important change for expatriates who have shares in foreign companies who will no longer be subject to taxes levied on unpaid income.
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.
KPMG in Slovakia
KPMG in Slovakia
GMS Flash Alert is a Global Mobility Services publication of the KPMG LLP Washington National Tax practice. The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organization. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. The information contained herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation.
© 2024 KPMG, an Irish partnership and a member firm of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
For more detail about the structure of the KPMG global organisation please visit https://kpmg.com/governance.
Lorem ipsum dolor sit amet, consectetur adipiscing elit, sed do eiusmod tempor incididunt ut labore et dolore magna aliqua.