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As local and international regulations become more prescriptive and enforcement gathers pace, dealing with the evolving tax landscape in a cross-border context presents you with a significant challenge. The number and complexity of tax investigations conducted by authorities is rapidly escalating and the need for tax adjustments is rising accordingly. Our 350 tax lawyers worldwide are supported by strong technical tax intelligence teams that identify developments in tax law and policy affecting your business. This multi-disciplinary approach helps you develop robust structures that maximise tax effectiveness in alignment with your commercial strategy. Given the cross-border nature of today’s tax issues, top corporates and financial institutions seek our advice in Central and Eastern Europe, given our global tax presence and our in-depth expertise in national tax laws.

Whether you are a financial institution, multinational, fund, investor or high net worth individual, we understand your business and the tax pressures you face. Our teams work together across Central and Eastern Europe and beyond in the key areas affecting your business including VAT, international taxation, transfer pricing, e-commerce, M&A and investment funds, tax planning and financing. Our experts can help you manage tax control cases and deal with tax authorities as well as manage tax litigation cases, including challenging tax liability decisions. The right tax advice can make a material difference to transaction costs and, in some cases, avert serious consequences.

Our team will provide you with advice and support in all the aspects of your business in Slovakia relating to tax law. Our experts in the Bratislava office will aid you in evaluating commercial contracts, in international transactions (including M&A) and in corporate restructurings. We are also well equipped to advise you on all corporate and project finance matters.

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29 April 2021
CEE Green­field Guide
CEE coun­tries have at­trac­ted sig­ni­fic­ant for­eign dir­ect in­vest­ment in green­field op­er­a­tions in re­cent years. In­deed, many man­u­fac­tur­ing busi­nesses have fo­cused on ex­pand­ing ca­pa­city in CEE coun­tries...
19 March 2021
New re­port­ing ob­lig­a­tions for cross-bor­der tax ar­range­ments
New re­port­ing ob­lig­a­tions for cross-bor­der tax ar­range­ments  The amend­ment to Act No. 442/2012 on In­ter­na­tion­al As­sist­ance and Co­oper­a­tion in Tax Ad­min­is­tra­tion, which entered in­to force on 1 Ju­ly 2020, in­tro­duces a new tax re­port­ing ob­lig­a­tion. From our ex­per­i­ence, tax­pay­ers are still in­suf­fi­ciently fa­mil­i­ar with this new re­port­ing ob­lig­a­tion.The re­port­ing ob­lig­a­tion stems from the EU Dir­ect­ive (DAC6) and aims to pre­vent ag­gress­ive and soph­ist­ic­ated tax plan­ning and sav­ings struc­tures. In­form­a­tion dis­closed to tax au­thor­it­ies in in­di­vidu­al EU Mem­ber States is sub­sequently ex­changed with tax au­thor­it­ies with­in the EU. What to re­port? The re­port­ing ob­lig­a­tion cov­ers cross-bor­der tax ar­range­ments that pose a risk of un­desir­able tax op­tim­isa­tion. To de­term­ine wheth­er there is such a risk, it must be as­sessed wheth­er the ar­range­ment in­cludes some of the char­ac­ter­ist­ic fea­tures con­tained in the An­nex to the Act (Hall­marks). Even per­fectly le­git­im­ate trans­ac­tions that do not aim to op­tim­ise tax—such as cus­tom­ary cross-bor­der trans­ac­tions between group mem­bers, or re­or­gan­isa­tions—may trig­ger a re­port­ing ob­lig­a­tion. For ex­ample: One com­pany in the group uses stand­ard mod­el doc­u­ments for its activ­it­ies that do not need to be sig­ni­fic­antly ad­ap­ted to the spe­cif­ic situ­ation (such as mod­el con­tracts for fin­an­cing or rent),Pur­chase of a loss-mak­ing com­pany, an­d­Cap­it­al­isa­tion of re­ceiv­ables (debt /equity swap).The re­port­ing ob­lig­a­tion does not af­fect the trans­ac­tion’s tim­ing (i.e., the tax au­thor­ity does not have to ap­prove the trans­ac­tion). A pen­alty of up to EUR 30,000 may be im­posed for breach­ing the re­port­ing ob­lig­a­tion. Who should make the re­port? In prac­tice, it is usu­ally the tax­pay­er who must make the re­port. Leg­al or tax ad­visors may also ful­fil the re­port­ing ob­lig­a­tion on the tax­pay­er’s be­half. However, this does not hap­pen auto­mat­ic­ally. The tax­pay­er must first in­struct his ad­visers to ful­fil the re­port­ing ob­lig­a­tion and then re­lease them from the duty of con­fid­en­ti­al­ity. In some oth­er Mem­ber States, by con­trast, the tax­pay­er’s ad­visors are the ones af­fected by the re­port­ing ob­lig­a­tion and must re­port the trans­ac­tion without re­gard to the cli­ent’s wishes. By when? The law provides for the fol­low­ing dates. The de­cis­ive date is the date on which the trans­ac­tion was car­ried out: by 31 Janu­ary 2021 for trans­ac­tions car­ried out between 1 Ju­ly 2020 and 31 Decem­ber 2020,by 28 Feb­ru­ary 2021 for trans­ac­tions car­ried out between 25 June 2018 do 30 June 2020, an­dup to 30 days after trans­ac­tions car­ried out on or after 1 Janu­ary 2021. To Dos   We re­com­mend that you check your pre­vi­ous cross-bor­der trans­ac­tions and im­ple­ment an in­tern­al mon­it­or­ing and eval­u­ation sys­tem. In ad­di­tion, we re­com­mend im­ple­ment­ing in­tern­al pro­cesses to en­sure you com­ply with the re­port­ing ob­lig­a­tion in a timely man­ner.
19 March 2021
News­let­ter 1 I Spot­light: Changes in the leg­al land­scape that af­fect your...
New ob­lig­a­tions for com­pan­ies The year 2021 sees new com­pany law ob­lig­a­tions for com­pan­ies. We out­line some of these here.  Please note that some new ob­lig­a­tions need to be ful­filled im­me­di­ately and...
30 December 2020
Stock sav­ings plan and Brexit: Brit­ish stock and some oth­er fin­an­cial in­stru­ments...
As a res­ult of Brexit, both stock or UCITS by a Brit­ish is­suer are dis­qual­i­fied and some EU-based UCITS funds’ un­der­ly­ing Brit­ish fin­an­cial in­stru­ments may also be so. Such a dis­qual­i­fic­a­tion may lead...
12 November 2020
Law and reg­u­la­tion of Cov­id-19 tax re­lief in Slov­akia
Value Ad­ded Tax Post­pone­ment for duty to sub­mit VAT re­turns for nat­ur­al per­son and jur­idic­al per­son un­til 30 June.Post­pone­ment for duty to sub­mit VAT re­turns and the dead­line to pay VAT on the basis...
Comparable
8 October 2020
Ex­CEEd­ing Bor­ders: In­dus­tri­al & Lo­gist­ics Mar­ket in CEE-17
The I&L sec­tor in the CEE-171 has be­come one of the most sought-after as­set types since 2019, after Of­fices and Res­id­en­tial ac­cord­ing to Col­li­ers In­ter­na­tion­al, CMS and Rand­stad “Ex­CEEd­ing Bor­ders:...
07 October 2020
Law and reg­u­la­tion of in­dus­tri­al and lo­gist­ics in­vest­ment in Slov­akia
1. Leg­al in­cent­ives for in­vest­ments spe­cific­ally in the I&L sec­tor in CEE-17 The spe­cial Act No. 57/2018 coll. on re­gion­al in­vest­ment aid and Gov­ern­ment Reg­u­la­tion No. 195/2018 Coll., provides sup­port...
Comparable
07 October 2020
Ex­CEEd­ing Bor­ders
Col­li­ers In­ter­na­tion­al­Luke Dawson - Man­aging Dir­ect­or & Head of Cap­it­al Mar­kets, CEEThe In­dus­tri­al&Lo­gist­ics (I&L) prop­erty sec­tor has ris­en out of the shad­ows over the last few years to be­come one of the most dy­nam­ic and stra­tegic­ally im­port­ant sec­tors in our eco­nom­ies and the com­mer­cial real es­tate sec­tor, on a glob­al basis. The I&L sec­tor is by no means a new kid on the block and for people out­side of this in­dustry, it may well largely go un­noticed as products and ser­vices are seem­ingly ma­gic­ally pro­duced and ap­pear in shops and on our door­steps. Be­hind the scenes, there is of course a gi­gant­ic sec­tor made up of man­u­fac­tur­ers, sup­pli­ers, re­tail­ers, 3PLs, dis­trib­ut­ors, stor­age and sup­ply chain com­pan­ies to name just a few, and they lit­er­ally touch any busi­ness or in­dustry sec­tor that you can pos­sibly ima­gine. In ad­di­tion to that, there are sev­er­al highly ex­per­i­enced, glob­al, re­gion­al and loc­al in­vestors and de­velopers that provide the li­on’s share of the prop­er­ties to make all this pos­sible.In this re­port, we look at how the I&L sec­tor has de­veloped in the geo­graph­ic­ally and macro-eco­nom­ic­ally stra­tegic re­gion of Cent­ral&East­ern Europe (CEE). We will also touch on some of the trends fa­cing the sec­tor, both from a prop­erty point of view, as well as from oc­cu­pi­er and con­sumer led stand­points. To­geth­er with our part­ners, we also provide valu­able in­sight in­to im­port­ant loc­a­tion se­lec­tion de­cision-mak­ing cri­ter­ia around la­bour mar­kets, tax and in­cent­ives offered to in­vestors con­sid­er­ing this re­gion.This re­port cov­ers a range of top­ics across 17 coun­tries in the wider CEE re­gion and as a res­ult, we have close to 100 pages of in­sights to share with you. There­fore, we would not ex­pect you to con­sume this all in one sit­ting and we hope this will be a use­ful tool longer term as you re­view the op­por­tun­it­ies in this great re­gion. Last, but not least, you can­not ig­nore the ele­phant in the room that is COV­ID-19. This pan­dem­ic that we are still very much in, has only con­firmed the stra­tegic im­port­ance and need for this sec­tor in un­cer­tain times, but has also high­lighted some areas for re­flec­tion. We hope you find this re­port use­ful and, wheth­er you are an in­vestor, de­veloper, oc­cu­pi­er or oth­er in­ter­ested party in the I&L sec­tor, we look for­ward to dis­cuss­ing your out­look and plans with you fur­ther.CMS and So­rain­en­Lu­kas Hej­duk - Part­ner, Head of CEE Real Es­tateOver re­cent dec­ades, coun­tries in the wider Cent­ral and East­ern Europe re­gion have at­trac­ted sig­ni­fic­ant levels of for­eign in­vest­ments. The well-edu­cated la­bour forces and lower la­bour costs than in West­ern Europe, rap­idly de­vel­op­ing in­fra­struc­ture with good trans­port links to the rest of Europe, tax ex­emp­tions and pref­er­ences for in­vestors, are only some of the reas­ons why nu­mer­ous com­pan­ies have de­cided to open man­u­fac­tur­ing fa­cil­it­ies and dis­tri­bu­tion centres in CEE.CMS and So­rain­en have provided their col­lect­ive know­ledge and ex­per­i­ence which is in­ten­ded to help po­ten­tial In­dus­tri­al&Lo­gist­ics in­vestors un­der­stand what in­cent­ives are avail­able when seek­ing to start op­er­a­tions in one or more of the 17 CEE coun­tries covered in this re­port. As there are vari­ous levels of sup­port across CEE, the fol­low­ing guide is presen­ted in a coun­try-by-coun­try format. It is not meant to be com­pre­hens­ive and gives more of a gen­er­al, in­dic­at­ive pic­ture. As laws and reg­u­la­tions can change quickly, it is vi­tal to seek pro­fes­sion­al ad­vice at an early stage if you de­cide to green light an in­vest­ment.Rand­stad­Paweł Ko­peć - Head of En­ter­prise Solu­tions CenterThe CEE re­gion has al­ways been among the first des­tin­a­tions in the minds of for­eign in­vestors, from the pro­duc­tion and lo­gist­ics sec­tors, when look­ing for sav­ings on per­son­nel costs and avail­ab­il­ity of the work­force. Over the years, la­bour mar­ket con­di­tions across the CEE coun­tries has changed rap­idly and, in some coun­tries, un­em­ploy­ment rates have fallen be­low levels that any­one could have pre­dicted a few years back, reach­ing nat­ur­al un­em­ploy­ment rates.Des­pite some of these factors, the CEE re­gion re­mains very at­tract­ive and has a lot to of­fer. Not only there are dif­fer­ences in la­bour avail­ab­il­ity and costs between the vari­ous coun­tries, there are also sig­ni­fic­ant dif­fer­ences between spe­cif­ic counties and cit­ies in the giv­en coun­try. New in­vestors will of course tend to feel more se­cure loc­at­ing their busi­nesses in areas already ex­plored by oth­er com­pan­ies, but those who take the risk and be­come pi­on­eers in less in­dus­tri­al­ized areas, may well be re­war­ded with loy­al per­son­nel and less work­force short­ages. In this re­port, we share our views on the vari­ous la­bour mar­ket con­di­tions and trends across the re­gion.25%me­di­um25%me­di­um25%me­di­um25%me­di­um
29 November 2019
Gibral­tar’s status with­in the EU
AG opin­ion ad­voc­ates strict in­ter­pret­a­tion of EU dir­ect­ive, but con­firms dis­crim­in­at­ory nature of Bul­gari­an le­gis­la­tion con­trary to free­dom of es­tab­lish­ment The opin­ion of Ad­voc­ate Gen­er­al Hogan (the...
19 August 2019
The ins and outs of Brexit – em­ploy­ment and tax as­pects
As the Brexit pro­cess ap­proaches its ex­ten­ded 31 Oc­to­ber 2019 dead­line, UK and EU com­pan­ies and their em­ploy­ees are fo­cus­ing on the key em­ploy­ment law and tax ques­tions that will shape busi­ness and the...
16 July 2019
An in­tro­duc­tion to the law of block­chain and dis­trib­uted ledger tech­no­lo­gies...
Data Pro­tec­tion The European Gen­er­al Data Pro­tec­tion Reg­u­la­tion raises at least two is­sues in par­tic­u­lar in this con­text. First: is pseud­onym­ous in­form­a­tion per­son­al data? Second: how can a “right...
11 July 2019
An in­tro­duc­tion to the law of block­chain and dis­trib­uted ledger tech­no­lo­gies...
Rem­ed­ies: In Prin­ciple The ori­gin­al Bit­coin White Pa­per stressed the im­port­ance of trans­ac­tions not be­ing re­vers­ible. Ir­re­vers­ib­il­ity is a func­tion of Bit­coin, de­lib­er­ately de­signed to re­duce trans­ac­tion...