Strategizing Multinational Tax Risks

Some interesting proposals to Slovakia’s tax code are highlighted for review, as detailed in the PwC summary in the attached link:

Click to access tax-and-legal-alert_4-2013_en.pdf

Interesting provisions include:

• Transactions will not be recognized if they have no business substance and their purpose is to avoid tax or attain a tax advantage that would not be otherwise attributable to the taxpayer
• Binding rulings will be available at the end of 2014
• The corporate income tax rate will decrease by 1% to 22% in 2014
• Net loss carryover period is shortened from seven to four years
• A tax license, from EUR 480 to EUR 2,880 will be introduced
• A service permanent establishment (PE) concept is created, provided it is recognized in the double tax treaty
• A new 35% withholding tax rate is introduced for payments to taxpayers from non-contracting states
• Transfer pricing documentation is to be provided within 15 days upon request

Slovakia’s proposals are further evidence of increased general anti-avoidance rules (GAAR) and emphasis on transfer pricing.