Did you know that in 2026 you may face top-up tax obligations alongside income tax?

Who does the top-up tax apply to?

If you are a member of a multinational group of enterprises or a large domestic group whose consolidated revenue reaches or exceeds EUR 750 million in at least two of the four accounting periods immediately preceding 2024, the following obligations apply to you:

• check whether you are required to calculate top-up tax or whether one of the exemptions (so-called safe harbours) applies to your company
• file a top-up tax return – even if the amount is nil
• file a notification with the information needed to determine the top-up tax, or a notification identifying the entity that filed it on behalf of the group
• pay the top-up tax if it arises

By when must the obligations be met?

The top-up tax applies for the first time for 2024, and the deadline for meeting the above obligations is 30 June 2026.

What does this mean in practice?

Assessing the application of the top-up tax and calculating it is a complex and time-consuming process. If you have not yet looked into this topic, we recommend starting as soon as possible. ⚠️

💡 Does the top-up tax apply to you too?

Our colleagues from the Forvis Mazars tax team in Slovakia, Andrea Cibulová and Milena Rážová, will be glad to advise you on how to prepare. Please don't hesitate to contact us using the details below.

The tax environment is currently highly dynamic. The information on our website is valid as at the date of its publication. Should you have any questions or uncertainties, please don't hesitate to contact us; we will be glad to assess the impact of a specific tax matter on your situation or company.