Date de publication : 06-10-1907
The following information are for the sole purpose of providing a general overview of the local taxation of the Corporate tax aspects of the country. In any case, it can not replace a tax advice, or be considered as an official information.
Yes we tax in Slovenia
New tax reform: No specific information
New tax treaties:
- Tax treaty between Slovenia and Vietnam is under negotiation.
Local tax advisors
No specific information on the local tax advisors.
The definition of Permanent Establishment follows the wording of article 5 of the OECD Model:
- Dependent agent who habitually concludes contracts in the name of a non-resident company (except if the activity is limited to purchase of goods);
- Fixed place of business, building site, construction, assembly or installation and any related supervisory activity, for a period of 12 months.
Resident companies are taxed on their worldwide income (« worldwide principle »). However, non-resident companies are only taxed on their revenues derived from Slovenia sources (« source principle »).
Entities are considered to be resident for tax purposes in Slovenia if their registered office is in Slovenia, or if their place of management & control is in Slovenia.
Note: the definitions of permanent establishment and place of residence are subject to the relevant provisions of any applicable double tax treaty, if any.
Corporate Income Tax
The general CIT tax rate is 19%.
Non-taxable income includes the following:
- Dividends received from qualifying participations;
- Certain capital gains deriving from qualifying participations;
Non-deductible expenses includes the following:
- Dividends benefiting from the participation exemption
- Interest in excess of the thin-capitalization threshold
- Fines and penalties
- CIT and similar taxes (including foreign withholding taxes)
- Late interest penalties related to payment of taxes
Carry forward: Yes indefinitely, but some restrictions may apply.
Carry back: No
Companies should submit the tax return annually before the 31 Match of the following year.
Annual tax returns are established by the company on a self-assessment system.
Companies shall pay monthly advance payments and the balance must be paid before 30 April of the following year (in the case where fiscal year coincides with calendar year).
Whithholding Taxes (payment to foreign companies)
The local tax rates in Slovenia are the following, subject to the provisions of an applicable double tax treaty, if any.
There is no WHT on the profits paid from a branch to its foreign head office.
The general rate of WHT on dividends is 15% of the gross amount.
The general rate of WHT on interest is 15%.
The general rate of WHT on Royalties is 15%.
The general rate of WHT on management fees is 0%.
The general rate of WHT on technical services is 0%.
Generally, capital gains are taxed under the regular CIT as general income.
Note: capital gains deriving from qualifying participation are exempt and capital gains deriving from building land are subject to a separate taxation.
Standard VAT tax rate is 22%
Reduced tax rates are:
- 5% (among others, foodstuffs, medicines, transport of passengers, books, …);
Zero-rated supplies include, subject to certain conditions:
- exports of goods;
- intra-Community supplies of goods;
- International passenger transportation;
Exempt supplies include, subject to certain conditions:
- Certain financial services ;
- Certain insurance services ;
- Training and education ;
Note: exempt transactions differ from zero-rated transactions in that the input VAT associated with exempt transactions is not deductible.
EU taxable companies may claim a VAT refund to their own tax authorities through on the basis of the 13th EU Directive.
In case where for a tax period, Input VAT exceeds Output VAT, certain non-resident companies (which are not required to register and incur Slovenia-VAT in the course of their business activities in Slovenia) may apply for a refund.
Refunds are subject to the reciprocity principle, which means that Slovenia only refunds VAT to foreign companies in countries that offer similar refunds to Slovenia companies.
No other specific information of VAT in Slovenia.
The general statute of limitation is 5 years starting at the end of the year in which the tax return had to be filed.
The statute of limitation could be extended to 10 years in certain cases.
There is no foreign exchange control in Slovenia. Income and capital could be freely repatriated.
There are thin capitalization rules in Slovenia. The interest derived from loans between related parties may not be deductible in case where interest exceeds some ratios (4 times the taxpayer’s net equity).]
Do not hesitate to share your experience in Slovenia with us in the comments below. Any comments are welcome !