Foreign entity

Does e-invoice apply to a foreign company registered under § 5 of the VAT Act?

⚠ Machine-translated answer, not yet manually reviewed. For the exact wording, see the Slovak original.

Short answer

No. According to the Financial Administration’s current FAQ, during the period from 1 January 2027 to 30 June 2030 a foreign person registered for VAT in Slovakia under § 5 is not required to issue e-invoices under § 85o or to ensure their receipt through a delivery service. A Slovak VAT identification number alone does not create those obligations because the transitional provision applies to domestic VAT payers registered under § 4, § 4b or § 4c and to domestic persons and transactions.

Section 5

Foreign person

Slovak registration does not create an obligation by itself Section 85o.

Section 4, Section 4b, Section 4c

Domestic payer

This heading is crucial for compulsory display.

Admission

No obligation

According to FAQ Section 5 the person in the transitional period does not need to provide reception through the service.

Period

Up to 30. 6. 2030

The conclusion concerns the transitional regime from 1. 1. 2027.

Detailed explanation

In the case of foreign companies, a distinction must be made between tax registration, place of establishment, place of supply and status in the specific transaction. Registration under Section 5 applies to foreign entities that register for Slovak VAT, but this does not confer the same status as that of a domestic taxable person under Section 4 or group registration under Section 4b. Therefore, the obligation to issue an e-invoice is not assessed solely on the basis of whether the entity has a Slovak VAT registration number, but according to the precise provision under which it is registered, and depending on whether Section 85o covers the case in question.

As set out in the law and technical rules

It is crucial to read Section 5 in conjunction with Section 85o of the VAT Act. The Financial Administration’s FAQ, in examples 29 and 52, expressly states that a person registered under Section 5 is not obliged, during the transitional period, to issue e-invoices or to ensure their receipt via a delivery service.

Practical examples

  • A Czech company registered in the Slovak Republic under Section 5 issues invoices using a Slovak VAT registration number. Under the transitional regime, Section 85o does not impose an obligation on it to issue a Slovak e-invoice.
  • The same person receives an invoice from a Slovak supplier. According to the current FAQ, they are not required to ensure receipt via a delivery service until 30 June 2030.
  • A Slovak s.r.o. registered under Section 4 is a different case, and the obligation is assessed under Section 85o.

Common misconceptions

  • “It has a Slovak VAT registration number, so it automatically issues e-invoices.” No. Registration under Section 5 is not the same as registration under Section 4, Section 4b or Section 4c.
  • “As a recipient under Section 5, it must have a post office box.” Not during the transitional period from 1 January 2027 to 30 June 2030, according to the current FS FAQ.
  • “Section 5 is the same as Section 4.” No. These are different registration regimes.

Conclusion

Foreign person registered by Section 5 is not in transition until 30. 1 June 2030 to obliged exhibitors or obliged recipients through a delivery service, Section 85o.

Legal and technical basis

  • Slovak Financial Administration, FAQ 9/VAT/2025/IM, examples 29 and 52
  • Act No. 222/2004 Coll. on VAT, Sections 4, 4b, 4c, 5 and 85o

Related questions

This does not constitute legal advice. Primary sources: FAQ Financial Administration of the Slovak Republic k e-invoice; Act No. 222/2004 Coll. on VAT as effective from 1. 1. 2027. Further sources: Act No. 222/2004 Coll. on VAT, Act No. 431/2002 Coll. on Accounting, Act No. 385/2025 Coll., official methodological and information materials from the Slovak Financial Administration on e-invoices, EN 16931, Peppol BIS Billing 3.0 and OpenPeppol eDelivery documentation. Verified on 13 July 2026.

Official cases from the Slovak Financial Administration’s FAQs

The following questions and answers are taken from the current July FAQ from the Financial Administration and have been assigned to this topic. Grouping the cases prevents the creation of duplicate pages, whilst retaining the full answer and the exact wording of the question.

Example No. 52: Does the e-invoice obligation also apply to a company with its registered office outside the Slovak Republic (but within the EU) which sells goods and services to Slovak companies registered for VAT, whilst issuing invoices under its own Slovak VAT registration number? The company is registered for VAT in the Slovak Republic pursuant to Section 5 of the VAT Act.

Under the transitional provision of Section 85o(2) of the VAT Act (effective from 1 January 2027), a taxable person under Section 4, 4b or Section 4c, who, from 1 January 2027, has supplied goods to a person referred to in paragraph 3 with a place of supply within the country as defined in Section 13, or who has supplied a service to a person referred to in paragraph 3 with a place of supply within the country as defined in Section 15 or Section 16, or who has received payment prior to such supply of goods or services, is obliged to issue an electronic invoice in accordance with paragraph 4; this does not apply if the supply of goods or services is exempt from tax under Sections 28 to 43 and 47, or if the taxable person issued a simplified invoice in accordance with Section 74(3)(a) or (b) upon the supply of goods or services. The above wording therefore does not apply to suppliers – taxable persons registered for VAT in the Slovak Republic under Section 5 of the VAT Act (i.e. not established in the Slovak Republic).

Example No. 29: Foreign companies (registered under Section 5) and e-invoices: Are foreign companies registered in the Slovak Republic under Section 5 also obliged to receive electronic invoices via a digital mailbox when they receive invoices from a Slovak supplier who will be obliged to issue and send e-invoices?

From 1 January 2027, the obligation to issue an electronic invoice is specifically regulated in the transitional provision of Section 85o(2) of the VAT Act, pursuant to which a domestic taxable person (Section 4, 4b or 4c) is obliged to issue an electronic invoice if they have supplied goods with a place of supply within the country pursuant to Section 13 of the VAT Act, or a service with a place of supply within the country pursuant to Section 15 or Section 16 of the VAT Act, or have received payment prior to such supply of goods or services, and the recipient of the supply is also a domestic taxable person (including a legal person) or a domestic non-taxable legal person. This transitional provision applies only to domestic persons and domestic transactions (Slovakia → Slovakia). A person registered under Section 5 of Act No. 222/2004 Coll. is not obliged, within the meaning of this transitional provision, to issue an electronic invoice, nor is it obliged to ensure the receipt of electronic invoices via a delivery service during the period from 1 January 2027 to 30 June 2030. We have also included a link to the relevant section of the Act: https://www.slov- lex.sk/ezbierky/pravne-predpisy/SK/ZZ/2004/222/?ucinnost=01.01.2027#paragraf-85o.nadpis

Primary source: Financial Administration of the Slovak Republic, FAQ 9/VAT/2025/IM k e-invoice, July 2026 update. Processed and checked on 13 July 2026.