Slovakia is incorporating further measures from the ViDA package into the VAT Act

The aim of the amendment to the VAT Act

The draft amendment to the VAT Act focuses primarily on the following objectives:

• the transposition of Articles 2 to 4 of Council Directive (EU) 2025/516, which forms part of the ‘VAT in the Digital Age’ (ViDA) package aimed at modernising VAT rules for the digital age – introducing amendments to the rules for the platform economy and extending the ‘single VAT registration’ system for VAT;
• amendment of the rules concerning the person liable to pay VAT on imports in the context of distance sales of goods imported from third countries, where the goods are subject to the special Import One-Stop Shop (IOSS), and the abolition of the special arrangements for the declaration and payment of VAT on the importation of goods (transposition of the related Council Directive (EU) 2025/1539).

Planned changes resulting primarily from the transposition of ViDA

The proposal includes, amongst other things, the following changes, which will come into force in several phases – on the date of publication of the legislation, from 2027 (primarily technical amendments) and from 1 July 2028 (platform economy and extension of the single VAT registration system):

On the date of publication of the legislation:

• clarification that the value of occasional property lettings is not included in the ‘turnover’ for registration purposes;

As from 1 January 2027:

• adoption of several technical legislative amendments relating to users of the One Stop Shop (OSS) and Import One Stop Shop (IOSS) schemes, and to operators of platforms and online marketplaces who facilitate the delivery made by original suppliers of consignments of goods imported from third countries into the EU;
• the creation of a legal fiction for a transitional period from 1 January 2027 to 30 June 2028, under which selected supplies of goods (e.g. gas, electricity, heating, cooling) to certain persons – generally final consumers (‘B2C’ supplies) – will, for the purposes of applying the special ‘one-stop-shop’ (OSS, Union scheme) scheme, be treated as distance sales of goods within the EU if the supplier is not established in the EU Member State of supply;

As from 1 July 2028:

• determination of the place of supply of a service consisting in facilitating the supply of a service to a person other than a taxable person through the use of various electronic communication interfaces – the place of supply is the same as that of the underlying service whose supply is being facilitated;
• the taxation of platforms in the short-term accommodation and passenger road transport sectors under the ‘deemed supplier’ regime, whereby the platform is treated as the person liable for VAT, except where the VAT is charged by the actual provider of such a service; the legal fiction of the deemed supplier does not apply even where, in the provision of the services in question within the EU, special TOMS rules apply;
• the adoption of extension of the so-called ‘Single VAT Registration’ system – ‘SVR’, which aims to eliminate the need for multiple VAT registrations in different EU Member States and enable businesses to fulfil most of their VAT administrative obligations through a single point of contact in their country of establishment – the reform will bring about the following main changes:
  • the scope of the ‘one-stop-shop’ (‘OSS’) scheme will be extended to new types of supplies of goods and services to certain persons – generally final consumers within the EU; this will include, amongst other things:
    • the supply of goods with installation and assembly,
    • the supply of goods on board ships, aircraft and trains during passenger transport within the EU,
    • the supply of gas, electricity, heating and cooling,
    • the supply of goods without dispatch or transport, as well as the supply of goods where transport begins and ends in the same Member State;
    • other supplies;
    • Similarly, subsequent transactions involving goods moved from one EU Member State to another will also be subject to specific rules;
  • a new OSS scheme will be introduced for the movement of own goods for business purposes to another EU Member State, thanks to which traders will no longer have to apply for VAT registration in the relevant country or pay VAT on the acquisition of goods – they will fulfil the related obligations via a single point of contact in their country of establishment;
  • in this context, the current call-off stock regime will also be phased out;
  • under the new rules, the reverse charge mechanism will also apply in cases where supplies of goods or services made in Slovakia are supplied by a foreign person (according to the explanatory memorandum, without a Slovak VAT identification number), to another foreign person who has been assigned a VAT identification number in Slovakia under Section 5 or is registered for VAT under Section 7 of the Slovak VAT Act;
• amendment of the rules governing the determination of the person liable to pay VAT on imports, based on the transposition of Council Directive (EU) 2025/1539, with the aim of strengthening the special scheme for distance sales of goods imported from third countries (‘Import One Stop Shop’ – ‘IOSS’):
  • where this scheme has not been applied to goods subject to the IOSS, liability for payment of the VAT shall pass to suppliers and platforms acting as deemed suppliers;
  • suppliers and ‘deemed suppliers’ will be required to appoint a tax representative in the EU Member State of importation, who will be liable for the VAT on importation where the supplier or ‘deemed supplier’ is not established in the EU but in a third country, with which the EU has not concluded a mutual assistance agreement;
  • at the same time, the application of the special rules for the declaration and payment of VAT on the importation of goods will be discontinued.

The draft amendment is currently undergoing a consultation process. We will keep you informed of further developments in the legislative process.