Konsolidačný balíček č. 3: čo sa mení vo svete daní?

Parliament has approved the third Consolidation Package, which introduces further measures to consolidate public finances starting next year. The National Council of the Slovak Republic has approved the law, which is currently awaiting the President’s signature before being published in the Collection of Laws. Below, we outline selected measures that may affect you in the upcoming period.

General tax amnesty

On 10 September 2025, as part of the package, the Slovak Government approved a regulation that allows for the waiver of penalties for non-payment of tax or for the submission of additional tax returns. This applies to all taxpayers in the following two situations:

• Tax underpayments recorded by 30 September 2025 – if the taxpayer pays these arrears between 1 January 2026 and 30 June 2026, no penalties (neither fines nor late payment interest) will be charged, or the arrears will be canceled in the amount of the corresponding penalties.
• Tax returns and additional tax returns with a submission deadline by 30 September 2025 – if the taxpayer submits their return and pays the tax between 1 January 2026 and 30 June 2026, no penalties will be imposed.

The amnesty does not apply to local taxes, special levies, tax advances or solidarity contributions.

Recommendation for you:

If you are aware of any tax risks or incorrectly calculated taxes in submitted tax returns, now is the ideal time to consider submitting an additional tax return. 

Definition of dependent work

The legal definition of dependent work in the Labor Code has been amended by removing the attribute “during working hours determined by the employer.”  The new wording primarily impacts assessment of the characteristics of dependent work when utilizing external workers (e.g., self-employed individuals). A labor inspector may argue that even with their own working time arrangement, an external worker fulfills the characteristics of dependent activity.

Recommendation for you:

We recommend taking a closer look at your current arrangements for cooperation with external collaborators and considering whether the change in definition could affect their tax or SSHI status.

Higher rates for higher personal income

In addition to the existing progressive rate of 19% (for a tax base up to approximately €44,000) and 25% (above approximately €44,000 and from the new year up to approximately €60,000), the new legislation introduces the following higher rate income ranges:

• Taxation of 30% on income between approximately €60,000 – €75,000
• Taxation of 35% on income above approximately €75,000

Multiples of the subsistence minimum determine the exact boundaries of the ranges.

Recommendation for you:

In view of an increasing burden on employee income, we recommend reviewing your remuneration structure for employees, especially those with higher incomes.

Minimum corporate tax for legal entities

Legal entities with annual taxable income exceeding €5 million will be required to pay minimum tax of €11,520. Other existing ranges for payment of minimum tax remain unchanged.

Recommendation for you:

When calculating minimum tax, it is important to consider the amount of taxable income (revenues) rather than the tax base.

Additional taxation of banks’ fees from gambling accounts

Beginning in the new year, bank revenues from fees for payment transactions in favor of gambling accounts via payment cards will be subject to 54% tax.

Selected changes in social and health contributions

Health contributions will increase from 4% to 5% for employees and from 15% to 16% for self-employed individuals and self-payers.

For self-employed individuals, the minimum assessment base for social contributions will also increase from 50% to 60% of the average wage from two years ago, and the period of contribution "holidays" will be reduced from one year to six months. 

Additionally, the period during which the employer pays wage compensation during sick leave is extended from 10 to 14 days, meaning that the Social Insurance Agency will pay sickness benefits starting from the 15th day of the employee’s inability to work.

Limitation of VAT deduction for cars used for private purposes

Beginning in the new year, a limitation applies to the deduction of VAT for motor vehicles also used for purposes other than business. We present this topic in detail in a separate alert here.

This change also impacts income tax – the portion of VAT that cannot be deducted is considered non-deductible for tax purposes and will not be included in tax expenses.

Recommendation for you:

If you are considering expanding your fleet with vehicles primarily used for business purposes, we recommend completing the purchase by the end of 2025.

Insurance premium tax and gambling levy

The tax on non-life insurance will increase from 8% to 10%. The levy for online games will increase from 27% to 30%, and the number of flat-rate levies on gambling in brick-and-mortar establishments will also change.

Higher special levy for pension funds, supplementary pension funds, and management companies

The rate of the special levy for pension and management companies will increase to 15% annually. If a regulated entity engages in multiple regulated activities, the higher rate will always apply.

Announced measures: Can we expect Consolidation Package No. 4?

Among the measures announced by the Ministry are potential additional burdens for banks, taxation of large retail chains, and taxation of digital services. Detailed information on these measures is not yet available, but we will continue to monitor the situation closely, to supply you with timely updates.

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If you are interested in the issue of paying advances to HICs and would like to learn more about the tax implications, do not hesitate to contact the authors of this article, Marta Onuščáková and Rút Kramerová.