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Law No 548/2010 introduced Article 51b, entitled ‘Tax on emission allowances’, which provided: ‘(1) For the purposes of the tax on emission allowances: (a) “taxable persons” are the participants in a trading scheme that carry out activities pursuant to the relevant provisions or that have been such participants for only a part of the relevant calendar year; (b) “registered emission allowances” are greenhouse gas allowances allocated free of charge to and registered to a taxable person under the relevant provisions in the relevant calendar year, including emission allowances acquired from another taxable person as a result of the purchase of an undertaking or part of an undertaking, a non-cash contribution in the form of an undertaking or part of an undertaking, or a merger or division of an undertaking or cooperative, which the receiving taxable person has acquired free of charge under the relevant provisions in the relevant calendar year; (c) “used emission allowances” are the certified emission reduction units (CERs) surrendered, in accordance with the relevant provisions, by the taxable person, from the greenhouse gas allowances allocated to that taxable person, in the relevant calendar year; (d) “transferred emission allowances” are greenhouse gas emission allowances transferred, in accordance with the relevant provisions, by a taxable person in the relevant calendar year from the emission allowances registered in that calendar year, with the exception of emission allowances transferred to another taxable person as a result of the sale of an undertaking or part of an undertaking, a non-cash contribution in the form of an undertaking or part of an undertaking, or a merger or division of an undertaking or cooperative; the transfer of emission allowances as a security for emission allowances registered to a taxable person that is a debtor, or their transfer back to a taxpayer who is a creditor, shall not be regarded as the transfer of emission allowances if that transfer has been made between the same persons, for the same sums and in the same units by, at the latest, the date of the surrender of the allowances to the registry administrator in accordance with the relevant provisions, in the relevant calendar year; (e) “unused emission allowances in the relevant calendar year” are the emission allowances registered in that calendar year less the emission allowances used in that calendar year, less the savings in allowances calculated in accordance with the relevant provisions and less the emission allowances transferred in the calendar year concerned; emission allowances registered in the relevant calendar year that have been transferred to another taxable person as a result of the sale of an undertaking or part of an undertaking, a non-cash contribution in the form of an undertaking or part of an undertaking, or a merger or division of an undertaking or cooperative shall not be regarded as unused emission allowances. (2) Emission allowances registered in 2011 and 2012 shall be subject to the tax on emission allowances. (3) The tax base for the tax on emission allowances shall be determined as the sum of the multiple of the emission allowances transferred in each calendar month and the average market price of emission allowances in the calendar month preceding the month in which the transfer is made and of the multiple of any unused allowances and the average market price of emission allowances in the relevant calendar year. … (5) The rate of the tax on emission allowances shall be 80% of the tax base of the tax … calculated in accordance with paragraphs 3 and 4. … (8) For the year 2011, taxable persons shall, by 30 June 2011 and by 31 December 2011, pay half-yearly advances of the tax on emission allowances each in the sum of one half of the anticipated tax. Taxable persons shall calculate each tax advance by applying the rate of the tax referred to in paragraph 5 to the amount calculated as the multiple of the average market price of emission allowances in 2010 and the registered emission allowances for 2011 less the actual allowances used in 2010 and any savings of emission allowances calculated in accordance with the relevant provisions. (9) For the year 2012, taxable persons shall, by 30 June 2012 and by 31 December 2012, pay half-yearly advances of the tax on emission allowances each in the sum of one half of the liability to the tax on emission allowances as stated in the declaration of revenue for 2011. … (12) The average prices of emission allowances for individual months and calendar years shall be published by the [Ministry of Finance of the Slovak Republic] on its website.’