Slovakia extends scope of “special method of tax payment” 1 Jan 2027
- 1 January 2027, the Slovak tax authority can mandate split payment by order where there is a reasonable concern a supplier will not remit VAT, requiring customers to pay the VAT element of an invoice directly to the tax authority while paying only the net amount to the supplier.
- Failure by the customer to comply carries severe risk, with penalties up to the full VAT amount shown on the invoice, making robust AP, treasury, and payment-control processes critical for affected businesses.
The change is part of Act No. 385/2025 Coll., and is explicitly positioned to address missing trader fraud risk by ensuring VAT is remitted to the tax authority even where a supplier may fail to pay. It also ties to the 2027 Slovakian e-invoicing mandate to help close the VAT Gap.
Other countries have variations of these mechanisms: Poland split payments applies to high fraud risk industries; Italy B2G split payments has been in place for almost ten years
How current “special method of tax payment” works
Under the special method, the customer does not pay the full gross amount to the supplier. Instead, the customer splits the settlement:
- Net (VAT base) is paid to the supplier; and
- VAT amount shown on the invoice is paid directly to the tax authority, to the bank account maintained for the supplier (referred to in the guidance as the supplier’s dedicated VAT payment account/identifier).
Conceptually, the tax authority “captures” the VAT at the point of payment, reducing the risk that VAT collected by the supplier is not later remitted.
Read more in our Slovakia VAT guide.
Tax authorities power to impose split payments Jan 2027
Historically, the special method functioned mainly as a customer-enabled protection in situations where the customer knew or should have known—based on sufficient reasons—that VAT would not be paid by the supplier. In other words, it was a risk-mitigation route for the customer to avoid joint-and-several exposure if a supplier defaulted.
From 1 January 2027, Slovakia expands this mechanism significantly by introducing a tax office decision-led model:
- Where the tax office has a reasonable concern that the supplier will not pay the VAT shown on the invoice by the due date, it may issue a decision requiring the customer to pay the VAT directly to the tax authority (to the supplier’s designated account/identifier).
- The decision will specify the period during which the customer must apply this method.
This is a key shift: the split-payment style method becomes not merely an option used defensively by customers, but a mandatory control imposed by the tax authority for targeted suppliers/transactions.
Practically, it affects B2B trading chains where the supplier issues an invoice charging Slovak VAT.
The change is also designed to be selective. The trigger is not universal application, but the tax authority’s assessment of risk (“reasonable concern”) that VAT will not be paid by the supplier by the due date.
What is the compliance risk for customers?
The amendment introduces a very direct enforcement lever: If the customer fails to pay VAT as required under the tax office decision (or pays only part), the tax office may impose a fine equal to the VAT stated on the invoice.
This is unusually punitive in its construction because the maximum penalty is not a percentage or capped amount; it mirrors the VAT amount that should have been protected. For customers, that means the control cannot be treated as an administrative formality—payment execution processes must be robust.
Practical actions for businesses
For businesses buying from Slovak suppliers, the main operational question is: can you execute a split settlement accurately, consistently, and at scale, when required?
The policy intent is to disrupt missing trader and carousel-style fraud patterns by re-routing VAT away from potentially non-compliant suppliers and into the tax authority’s hands at the payment stage. In effect, it reduces the opportunity for VAT “leakage” between invoice issuance and VAT return/payment cycles.
It also signals a broader trend across Europe: tax authorities are increasingly combining e-invoicing / digital reporting with payment controls. In Slovakia, the split-payment decision model sits alongside the wider move to mandatory structured e-invoicing and near-real-time reporting (from 2027 transitional arrangements, and then ViDA Digital Reporting Requirements measures from July 2030).
