Top-up tax: new obligations for large groups

The top-up tax applies to Slovak companies and permanent establishments belonging to groups with a consolidated turnover of at least EUR 750 million in at least two of the last four years.

Obligations and filing deadlines

Every entity to which Pillar 2 applies must submit:

• a GloBe Information Return (GIR) or a notification stating which entity within the group has filed the GIR on behalf of the group,
• a tax return for the adjustment tax.

These obligations apply even if no top-up tax is due, and each Slovak entity is required to file a tax return separately.

The effective tax rate is calculated per country, and the adjustment tax is then allocated among the individual companies in that country according to an allocation formula.

The deadlines depend on the accounting period:

• for the 2024 calendar year, the deadline for the GIR and the tax return is 30 June 2026,
• for a financial year, the deadline for the first tax period commencing no earlier than 31 December 2023 is 18 months from the end of that period,
• for subsequent tax periods, the deadline will be 15 months after the end of the period (e.g. for the calendar year 2025, by 31 March 2027).

If you need advice on Pillar 2 or require assistance with the calculation and preparation of the necessary filings, we would be happy to help.