Slovenia country profile | KPMG | GLOBAL

Slovenia country profile

Slovenia country profile

Key tax factors for efficient cross-border business and investment involving Slovenia.

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EU Member State

Yes

Double Tax Treaties

With: 

Albania  Egypt(a) Kazakhstan
Romania 
Armenia  Estonia  Kosovo 
Russia 
Austria  Finland  Kuwait 
Serbia 
Azerbaijan  France  Latvia 
Singapore 
Belarus  Georgia  Lithuania 
Slovakia 
Belgium  Germany  Luxembourg 
Spain 
Bosnia
& Herzegovina 
Greece  Macedonia 
Sweden 
Bulgaria 
Hungary  Malta 
Switzerland 
Canada 
Iceland  Moldova 
Thailand 
China 
India  Montenegro 
Turkey 
Croatia 
Iran  Netherlands 
UK 
Cyprus 
Rep. of
Ireland 
Norway 
Ukraine 
Czech Rep. 
Israel  Poland 
UAE 
Denmark  Italy  Portugal 
US 
  Rep. of
Korea 
Qatar 
Uzbekistan 

 

Note: (a) Treaty initialed/signed/approved, but not yet in force.

Most important forms of doing business

Limited liability company and joint-stock company, also limited and general partnerships.

Legal entity capital requirements

Share capital: EUR 7,500 for limited liability company and EUR 25,000 for joint stock company.

Residence and tax system

Legal entities having their legal seat or place of effective management in the territory of Slovenia are residents for income tax purposes.

Resident companies are taxed on their worldwide income. Non-resident companies are taxed on their Slovenian source income only.

Compliance requirements for CIT purposes

Fiscal year can equal or deviate from the calendar year. In general, submission of the CIT return to tax authorities within 3 months after the end of the fiscal year.

Corporate income tax rate

The standard corporate income tax rate is 19 percent.

Withholding tax rates

On dividends paid to non-resident companies

Vary between 15 percent and exemption.

On interest paid to non-resident companies

Vary between 15 percent and exemption.

On patent royalties and certain copyright royalties paid to non-resident companies

Vary between 15 percent and exemption.

On fees for technical services

No, unless services paid to a company located in tax haven and such country is listed on a "black list" published by the Ministry of Finance in Slovenia.

On other payments

See above.

Branch withholding taxes

See above.

Holding rules

Dividend received from resident/non-resident subsidiaries

Exemption. No participation requirement or minimum holding period is required. Exemption does not apply where the dividend paying company is resident in a non-EU jurisdiction where the general or average nominal tax rate is lower than 12.5 percent and which is included on a “black list” published by the Ministry of Finance.

Capital gains obtained from resident/non-resident subsidiaries

50 percent exempt if certain conditions are met:
  • Participation requirement: 8 percent;
  • Minimum holding period: 6 months;
  • At least one employee employed on a full-time basis in the period concerned;
  • The participation should not be held in a company that is resident in a non-EU jurisdiction where the general or average nominal tax rate is lower than 12.5 percent and which is included on a “black list” published by the Ministry of Finance.

Tax losses

Tax loss may be carried forward without limit and may be utilized up to the amount equal to 50 percent of the positive taxable basis.

No carry back of losses.

If during a tax period, the ownership of equity capital and/or equity holdings or voting rights of the taxpayer changes directly or indirectly by more than 50 percent compared to the state of ownership at the beginning of the tax period and the taxpayer (i) did not perform the activity two years prior to the change in ownership; or (ii) considerably changed the activity two years prior to or after the change in ownership, accumulated tax losses, as well as losses relalized in the year of the change in ownership, cannot be carried forward.

Tax consolidation rules/Group relief rules

No

Registration duties

No

Transfer duties

On the transfer of shares

No

On the transfer of land and buildings

2 percent Real Estate Transfer Tax.

Stamp duties

No

Real estate taxes

No

Controlled Foreign Company rules

No

Transfer pricing rules

General transfer pricing rules

Yes 

Documentation requirement

Yes 

Thin capitalization rules

Yes, the debt-to-equity ratio is 4:1.

General Anti-Avoidance rules (GAAR)

Yes

Specific Anti-Avoidance rules/Anti Treaty Shopping Provisions

Principle "substance over form" - Tax Procedure Act.

Advance Ruling system

Binding ruling may be obtained in some cases. Advanced Pricing Agreements may be concluded for transfer pricing issues.

IP / R&D incentives

Yes

Other incentives

40 percent investment incentive on intangible assets and equipment (except for office equipment and furniture).

100 percent tax allowance for R&D expenses.

VAT

The standard rate is 22 percent, and the reduced rate is 9.5 percent.

Other relevant points of attention

No

Contact us

Mehle Marko

KPMG in Slovenia

T: +38614201153

E: marko.mehle@kpmg.si

EU Tax Centre

KPMG’s EU Tax Centre, working together with our network of EU tax law specialists throughout the European Union.

 
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