Slovakia has withdrawn several long-standing reservations and aligned more closely with the OECD standard in areas including:

• construction permanent establishments (12-month threshold),

• maximum withholding tax on interest (10%),

• taxation of leasing income from ships, aircraft and containers,

• treatment of software-related payments,

• interpretation of business profits under Article 7.

At the same time, selected positions have been maintained, particularly in the area of dispute resolution (mandatory arbitration) and supervisory activities.

For multinational groups, investors and companies engaged in cross-border activities, these developments affect treaty interpretation, structuring decisions and tax risk assessment. The changes primarily apply to new treaties concluded after the updated Commentary, while existing treaties remain unaffected.
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Our detailed report provides:

• a structured overview of each amended article,

• analysis of withdrawn and maintained reservations,

• practical interpretation of key changes,

• implications for Slovak taxpayers and foreign investors.
  
   

Download the full report to understand how the updated OECD Commentary may impact your international tax position and future structuring decisions.