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Slovakia

Slovakia offers a 100% deduction of eligible costs from the income base, providing a net benefit of 21% on the cost of R&D. There is an additional 100% deduction that can be applied to any incremental year-on-year increase of QE, equating an additional 21% net benefit.

There is continued lack of clarity regarding how the legislation should be interpreted, which can make it difficult to engage with the relevant authorities.

The Finance Administration publishes a list of all the companies which have applied for the R&D Tax deduction, which includes a short description of each R&D project. This means there is a potential risk of sharing sensitive information with competitors.

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All Companies
100% for all QE in current year and an additional 100% of any additional QE (average of current and previous year) over and above the average of the two previous years. The net benefit equals 21%.
Benefit Overview
Slovakia offers a 100% deduction of eligible costs from the income base, providing a net benefit of 21% on the cost of R&D. There is an additional 100% deduction that can be applied to any incremental year-on-year increase of QE, equating to an additional 21% benefit.
Eligible Claim Period
The company can look back retrospectively for one financial year and the claim must be made within three months of year-end, as an input into the tax computations (immediate relief). The company can request a 'delay' to submit 6 months of previous financial year (i.e. Dec Y/E – submit half at the end of March and remained end June, both directly into tax comps).
Historical Background
The regime, based on the Czech one, has been valid since January 2015, but with only a 25% benefit on QE.
As of January 2018 it is possible to claim 100% of R&D costs in the year, plus an additional 100% for any incremental QE over and above the average of the two previous years.
Ease of Application

There are 2 main conditions:

  • The company must have an internal simple entry document created for every R&D project for which it claims the applicable costs for tax deduction. The document must contain the date, project start and end dates, the goals that they want to achieve with the project and the estimated costs for the project for each year. The document must be approved by a person who can act on behalf of the company.
  • Company must separate the R&D costs for each project into individual analytical accounts.

The company applies the tax deduction in the tax declaration by filling out an annex to the tax return which contains data from the entry document and the applicable deduction.

Regulating Body Policies

The company must show the Finance Administration the internal simple entry document within 8 days of audit or enquiry being opened by the tax authority.

The law itself was created by the Ministry of Finance, while the application of the legislation in practice is carried out by the guidelines and FAQs written by the Financial Administration, a bureau within the Ministry of Finance.

Eligible Costs

The following are the eligible costs for the regime:

  • Salary
  • Materials
  • Amortisation of equipment & buildings
  • Software licences (for R&D purposes)
  • Running costs (electricity, water, heat, gas)
  • Non-material development results bought from R&D companies certified under the Ministry of Education (only about 200 companies, universities and academic institutions)
  • Certification of the R&D results (e.g. homologation)

If full or partial funding from public resources is received for any of the costs, this deems them ineligible.

Issues to Consider
  • The Finance Administration publishes a list of all the companies which have applied for the R&D Tax deduction, which includes a short description of each R&D project. This means there is a potential risk of sharing sensitive information with competitors.
  • R&D tax cannot be combined with any other types of incentives.

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