Most of the changes in the recently passed revision to the Income Tax Act is restrictive and aimed against aggressive tax planning, writes Renáta Bláhová, partner at BMB Leitner, on her blog. The measures include taxation of Slovak owners of foreign companies, taxing the exit of companies, restricting tax neutrality for corporate reorganizations, and a 35% withholding tax on payments where the final beneficiary is unidentified. Other changes in the revision are pro-business, such as an increase in the research tax deductible from 25% to 100%, the so-called Patent Box (exempting 50% of copyright income) and a capital gains tax exemption when an ownership stake tops 10% for at least two years. The tax authority FS will also adopt a tax reliability index, and extend the limit for filing an appeal from 15 to 30 days. Bláhová says the revision thus removed the last legitimate reasons for Slovak businesspeople to optimize their tax burden via complicated international structures.