Pay attention about change of obligations for entrepreneurs

Written by Mgr. Peter Neštepný

Let us inform you that with effect from November 15th, 2021, the taxpayer is obliged to notify the Financial Directorate of the Slovak Republic of each of his own bank accounts that he will use for business that is subject to VAT, immediately from the day he became a taxpayer or from when you set up such a bank account.

This obligation applies to all payer's bank accounts meeting the above definition and any changes, additions or cancellations must be notified to them without delay.

The notification is made electronically, using the appropriate functionality (form) published on the website of the Financial Directorate of the Slovak Republic ( After the entry into force of the law, a transitional period is set for the fulfillment of the notification obligation for existing payers - until November 30th, 2021. The penalty for non-compliance is a fine of up to € 10,000

The bank accounts thus announced will be published.

In addition to the notification of bank accounts, we also draw attention to the related effects concerning the already existing VAT liability institute (effective from January 1st, 2022). The two that we consider to be the most important are:

  1. Addition of a new letter c) to § 69 par. 14 of the Act, which defines which reasons are presumed as reasons when the payer should have known or could have known that all or part of the tax on goods or services will not be paid.
    It will also be considered as such a reason if the payment is made to a bank account other than the one currently announced (on the day of the transfer).
    Therefore, if the payer wants to avoid the risk of liability for the supplier's tax, he will have to monitor / verify the status of the disclosure of the accounts of his suppliers when making payments. We only note that the reasons defined so far, when the liability of the payer arises (letters a) and b) § 69 par. 14 of the Act remain unaffected by this).
  2. If the taxpayer considers ("knew or should have known or could have known for sufficient reasons referred to in § 69 (14)") that the tax stated on the invoice will not be paid by the supplier, he may pay it directly to the tax administrator's account number kept for the supplier (at the latest before the delivery of the decision on the obligation to pay the tax to the payer as guarantor). In such a case, the liability and procedure pursuant to Section 69b of the Act shall not apply.
    We will only add that if the supplier still pays the tax, he will settle it as a tax overpayment.

Of course, the amendment has a much broader scope and also touches on other legislation; the above is a description of only a small part of it, which, in our experience, we consider to be (at this time) the most important.

In this regard, we recommend that you consider modifying your model contracts or general terms and conditions and increase your suppliers' control over individual payments.

The full approved text is currently available at:

The stated law was approved by the National Council of the Slovak Republic on October 27th, 2021 and signed by the President of the Slovak Republic on November 8th, 2021. It has not yet been published in the Collection of Laws, but there is no doubt that this will happen in the near future.

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