Page 52 - CEE Tax Guide 2025

Slovenia

Forvis Mazars Consulting d.o.o.
Verovškova ulica 55A 1000
Ljubljana, Slovenia
Phone: +386 59 049 500
www.forvismazars.com/si

Corporate taxes and other direct taxes Tax allowances exist for new investments, R&D,
employment of disabled persons, donations, and
From January 1, 2024, to December 31, 2028, since 2022, for the digital and green transition.
the corporate income tax (CIT) rate increases The amendment from 2024 allows the unused
to 22% (previously 19%). The tax base is the pre- portion of the digital and green transition
tax profit, adjusted by specific items. A 0% rate investment allowance to be used over five tax
applies to investment funds, pension funds, and periods after the investment period. This applies
insurance undertakings for pension plans under to investments made after the amendment
certain conditions.
becomes applicable.
Companies in international maritime shipping can
opt for the tonnage tax regime with prior notification. GAAR and CFC rules apply since 2019. Interest
Tax losses can be carried forward up to five tax deduction is limited to 30% of EBITDA or EUR
periods, but used only up to 50% of the tax base, 3 million (whichever is higher), following ATAD.
with special rules for M&A. A withholding tax of 15% is applied to dividends,
interest, royalties, and rental income paid
by a Slovenian company to a foreign company.
Transfer pricing in Slovenia
However, if conditions are met, an exemption
Arm’s length principle Since 2005, in Article (or decrease in the percentage of withholding tax)
16 of the Slovene Corporate is applicable to payments to EU residents (under the
IncomeTax Act (CITA).
Parent Subsidiary Directive & the interest and royalty
Documentation liability Slovene Ministry directive), and under international double taxation
of Finance issued
regulations treaties (there are currently over 60 treaties).
on TP on January 1, 2007.
• Real estate transfer tax (RETT) is applied on the
APA Available transfer of immovable property at the rate of 2%
if the transaction is not subject to VAT, where the
Country-by-Country Since 2016
liability tax base is the sale price.
• DAC7 obligatory reporting from period 2023
Master file-local file Since 2006
(OECD BEPS onwards – with first reporting due date
13) applicable on January 31, 2024.
Penalty • On December 13, 2023, the National Assembly
adopted the Minimum Tax Act. In brief, the
lack of documentation Penalty up to EUR 30,000. new act will introduce an additional tax liability

tax shortage 30% of underpaid tax from 2024 onwards for groups whose annual
for micro and small revenue in at least two of the last four financial
legal entities.
years amounts to 750 million EUR or more
Related parties Transfer pricing on a consolidated level.
regulations is based
on OECD guidelines. This is so-called top-up tax, which is levied on the
Safe harbors Administratively excess profits if a group reaching the threshold
determined recognized does not reach the minimum effective tax rate
interest rate for all of 15% in a specific jurisdiction. Obliged groups
loans between RPs.
will be required to prepare an annual return as well
Level of attention paid 9/10 as a domestic top-up tax return, whether they are
by Tax Authority liable to pay it.

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