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Slovak Republic: Tax rules for controlled foreign companies
A closer look at the CFCs new rules for companies with a registered office abroad December 11 2020
Tax rules for controlled foreign companies (CFCs) were introduced into Slovak law as of January 1 2019 with the implementation of the EU s Anti-Tax Avoidance Directive (ATAD). For the time being, the CFC rules only apply to Slovak controlling companies. Beginning on January 1 2021, an expected expansion of the CFC rules will include individuals who control CFCs pursuant to the government s bill that is slated to be passed by parliament before year s end.
By definition, a Slovak controlling company of a CFC is a company whose registered office, as indicated in the commercial register, or place of effective management is in the Slovak Republic. The law stipulates that the place of effective management is in Slovakia if it is the place where management and business decisions are taken by the directors a