Worldwide tax residence
Where you are a tax resident decides where you tax your worldwide income. We assess your residence, the consequences of changing it and the related obligations — soberly, transparently and without promises of a specific tax outcome.
JUDr. Ondrej SteinigerPartner · Attorneyondrej.steiniger@steinigers.com
JUDr. Viktória KertészováAttorneyviktoria.kerteszova@steinigers.comTax residence and changing it
Tax residence is not about an address on paper but about where you really live and run your affairs. We assess it correctly and comprehensively.
Residence criteria
An individual's tax residence is assessed under § 2 of Act No. 595/2003 Coll. on income tax — chiefly the permanent home and habitual abode in Slovakia. A resident taxes worldwide income. Where a person is resident in two states, the tie-breaker test of the relevant double tax treaty applies.
Assessment and change plan
For a contemplated change of residence we assess whether and on what conditions it would actually occur and prepare the procedure including documentation. The tax side is covered under Tax and tax disputes.
Exit tax and consequences
Leaving tax residence can trigger taxation even before you go. We assess the consequences so nothing surprises you.
Exit tax
On moving tax residence or assets abroad, an exit tax may apply under § 17f of Act No. 595/2003 Coll., taxing unrealised gains on assets on departure (implementing the ATAD Directive). We assess whether and to what extent it affects you.
Consequences for income and assets
We evaluate the impact on individual types of income and assets, including controlled foreign company (CFC) rules. The specific outcome depends on the facts and we do not guarantee it.
Reporting and substance
Transparency is now a condition, not an obstacle. We set up reporting and documentation so your position holds up.
CRS, DAC6 and reporting
We take account of automatic exchange of financial account information (CRS) and reporting of cross-border arrangements (DAC6). We help meet obligations and maintain a transparent position.
Substance and evidential position
In a change of residence, a genuine link to the new state and supporting documentation are key. Wider structures are covered under International business structures.
We follow legislation for you.
The branch of a foreign company and the Hungarian fióktelep: standing, liability, registration and taxation
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The lawyers at Steiniger always advised us very quickly and effectively — whether it concerned copyright, trademarks or corporate matters."
Filip Glasa · CEO, FinStat
Dozens of cases in which our clients protected their brands thanks to the prompt and professional help of the Steiniger team."
Michal Pastier · GoBigname
We found someone with whom we handle things comprehensively and reliably — from commercial and copyright law to taxes."
Matej Drlička · CEO, VivaMusica / IXPO
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Memberships
We are part of communities that shape law, business and culture.
FINASFintech & Insurtech Association of Slovakia
SKMASlovak Cryptocurrency Association
Forbes Grow ClubBusiness club of an elite community of top Slovak entrepreneurs
SING!Patrons’ club of the Bratislava Boys’ Choir
For business owners ◆ investors ◆ CFOs and finance directors
Hungary:how to do business and invest in real estate
SK vs. HU. The differences that matter.
Let us take responsibility for your decisions in life and business.