Minimum corporate tax (tax licence) for s.r.o. in 2026: new tier €11,520
From 2026, the minimum corporate tax system is extended with a new, highest tier of €11,520 for companies with taxable revenues (income) above €5,000,000. How does the tax licence work, who does it apply to and how do you calculate it correctly?
Ing. Marián Drozd
Tax advisor, 20+ years of experience
New tier from 2026!
A new, highest minimum tax tier of €11,520 is introduced for companies with taxable revenues (income) above €5,000,000. The existing tiers remain in force.
What is the minimum corporate tax (tax licence)?
The minimum tax is an amount that a legal entity (s.r.o., a.s.) must pay to the state regardless of whether it makes a profit or a loss. It is a minimum floor of corporate income tax that cannot be optimized below this level.
How it works
If your calculated corporate income tax is lower than the minimum tax, you pay the minimum tax. If your calculated tax is higher, you pay the actual tax (the minimum tax does not apply).
Example 1: Loss-making company
Taxable revenues (income): €800,000
Result: loss -€20,000
Corporate income tax: €0
→ Pays minimum tax: €3,840
Example 2: Profitable company
Taxable revenues (income): €800,000
Profit: €100,000
Corporate income tax: €21,000 (illustrative)
→ Pays actual tax: €21,000 (higher)
Minimum tax tiers from 2026
| Taxable revenues (income) | Minimum tax | Per month |
|---|---|---|
| up to €50,000 | €340 | ~€28 |
| €50,001 – €250,000 | €960 | €80 |
| €250,001 – €500,000 | €1,920 | €160 |
| €500,001 – €5,000,000 | €3,840 | €320 |
| over €5,000,000 (NEW) | €11,520 | €960 |
Watch the new tier!
Companies with taxable revenues (income) above €5 million must count on a minimum tax of €11,520 per year from 2026, even if they make a loss (unless they fall under an exemption under § 46b(7)). This is a monthly cost of €960.
Who pays the minimum tax and who doesn't?
DOES pay minimum tax:
- • All s.r.o. and a.s. registered in Slovakia
- • Cooperatives and other legal entities
- • Companies in loss or with low tax
- • Companies with low or zero taxable revenues (income) (typically the minimum tier €340)
- • Holding companies
DOES NOT pay minimum tax:
- • Sole traders (SZČO) (individual entrepreneurs)
- • Companies in their first tax period (first corporate tax return)
- • Taxpayers under § 12(3) and (4) (typically non-profits, municipalities, etc.)
- • Companies whose actual tax exceeds the minimum tax
Exemption for new companies
Newly established companies (in their first tax period) do not pay the minimum tax. The exemption is designed to support new entrepreneurs.
Crediting the minimum tax in future years
An important feature of the minimum tax: if you pay it in a loss year, you can credit it against corporate tax in subsequent profitable years.
Crediting example:
Crediting limitation
Crediting is possible only up to the difference between the actual tax and the minimum tax. You cannot reduce your tax below the minimum tax level. The time limit for crediting is 3 years.
How to (legally) optimise minimum tax
1. Monitor taxable revenues (income) around the tier thresholds
If you are just above a threshold (e.g. taxable revenues €510,000), consider whether some revenues can be shifted to the next year. Beware of anti-abuse rules.
2. Split activities into multiple companies
With very high taxable revenues, it can be beneficial to split activities into separate companies. Each company pays minimum tax based on its own taxable revenues (income). Consult a professional.
3. Keep records for crediting
Keep track of minimum taxes paid in loss years. Don't forget to apply them in profitable years (the 3-year time limit).
4. Liquidate inactive companies
If you have an inactive company with low or zero taxable revenues, you typically pay the minimum tax of €340. Consider liquidation if you do not plan to use the company.
Payment and deadlines
Due date
The minimum tax is paid together with the corporate tax return, i.e. by the tax return filing deadline (typically 31 March; later if an extension applies).
Reporting in the tax return
The minimum tax is reported in the corporate income tax return in the section dedicated to the minimum tax (based on the current form). The system compares it with the calculated tax.
Frequently asked questions (FAQ)
Do I pay minimum tax if I have a company but do not operate?
Usually yes: if you file a corporate tax return and do not fall under an exemption under § 46b(7), the minimum tax applies even with low or zero taxable revenues (income).
How are taxable revenues (income) determined for minimum tax purposes?
The decisive amount is the taxable revenues (income) for the tax period under § 46b(2) (not only “sales turnover”).
What if my taxable revenues (income) change during the year?
The decisive amount is the taxable revenues (income) for the entire tax period. If the tax period is shorter than 12 months, the minimum tax is calculated proportionally (1/12 × number of months).
Can I deduct the minimum tax as an expense?
Not directly. The minimum tax is not a tax-deductible expense. However, the minimum tax paid can be credited in future profitable years.
Need to optimise minimum tax?
We can help you analyse your situation and find legal ways to optimise your tax burden.
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