Slovenia Tax Regime

Slovenia operates a classical corporate income tax system alongside a progressive personal income tax with flat, generally final taxation of capital income. Resident companies are taxed on worldwide income at a flat 22% rate — temporarily elevated from 19% for the years 2024 to 2028 to help finance reconstruction after the August 2023 floods — with a second layer of tax on distributions to shareholders. As an EU member state, Slovenia applies the Parent-Subsidiary, Interest-Royalties and Anti-Tax-Avoidance Directives, follows OECD standards on treaties and transfer pricing, and has implemented the Pillar Two global minimum tax through its Minimum Tax Act (ZMD) with effect from 2024. Administration through the Financial Administration (FURS) is fully electronic and generally predictable.

1.1 Sources

Primary legislation includes the Corporate Income Tax Act (ZDDPO-2), the Personal Income Tax Act (ZDoh-2), the VAT Act (ZDDV-1), the Tax Procedure Act (ZDavP-2) and the Minimum Tax Act (ZMD).

1.2 Recent developments

The headline corporate rate was raised from 19% to 22% for the years 2024 through 2028 under the post-flood reconstruction law, which also introduced a temporary 0.2% balance-sheet tax on banks for the same period; corporate prepayments are calculated at the 22% rate. The Minimum Tax Act transposing the EU global minimum taxation directive took effect at the end of 2023, applying the income inclusion rule, the undertaxed profits rule as a backstop and a qualified domestic minimum top-up tax (QDMTT) for financial years from 2024. The ATAD-style 30% EBITDA interest limitation replaced the former 4:1 thin-capitalisation ratio, the VAT registration threshold was lifted to EUR 60,000, and a compulsory long-term care contribution of 1% each for employees and employers applies to payroll from mid-2025.

Headline statutory corporate income tax rate for a resident company. Where sub-national (state, provincial, cantonal or municipal) corporate taxes apply, the combined rate reported by the OECD is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

Top marginal statutory personal income tax rate on employment income for a resident individual. Where sub-national (state, provincial, cantonal or municipal) income taxes are a standard part of the system, the combined top rate is shown. Projected 2026–2028 rates carry the current rate forward unless a change is already enacted or officially scheduled. As-of 2026.

2.1 Rates and residence

Companies — principally the d.o.o. (limited liability company) and d.d. (joint-stock company) — are subject to corporate income tax at a flat 22% (2024–2028; the permanent statutory rate is 19%) on worldwide income if they have their registered seat or place of effective management in Slovenia. Non-residents are taxed only on Slovenian-source income, including profits attributable to a Slovenian permanent establishment. There are no municipal or local income taxes. Non-profit organisations are exempt on their non-profit activities, and investment funds, pension funds and pension insurance companies may qualify for a 0% rate under conditions. Shipping companies in international maritime transport may opt into a tonnage tax computed on net tonnage per operating day instead of ordinary CIT.

2.2 Dividends and participation exemption

Dividends and profit shares received by a Slovenian company from domestic, EU or treaty-comparable foreign subsidiaries are excluded from the tax base, provided the payer is not resident in a listed low-tax jurisdiction (general profit-tax rate below 12.5%); 5% of the exempt dividend is treated as non-deductible cost, giving an effective 95% exemption. Capital gains on qualifying participations — at least 8% of capital or voting rights held for at least six months, with at least one person employed full-time — are 50% exempt, with 5% of the exempt part added back as deemed costs (an effective 47.5% exemption); corresponding losses are only 50% deductible.

2.3 Income determination and deductions

The tax base starts from the profit shown in statutory accounts prepared under Slovenian accounting standards or IFRS, adjusted for tax rules. Business expenses are deductible if directly connected with taxable revenue; entertainment costs and supervisory-board fees are only 60% and 50% deductible respectively, and fines, bribes and income-tax charges are non-deductible. Tax depreciation is straight-line at maximum prescribed rates — buildings 3%, equipment and vehicles 20%, computer hardware and software 50%, goodwill amortisation is not deductible on acquisition of a business as a going concern beyond prescribed limits. Provisions are broadly 50% deductible on formation, with the balance recognised on utilisation. A combined cap applies to reliefs: tax allowances and loss carryforwards together may not reduce the annual tax base by more than 63%, so at least 37% of the base is always taxed.

2.4 Interest limitation

In line with the EU Anti-Tax-Avoidance Directive, exceeding borrowing costs are deductible only up to the higher of 30% of tax EBITDA or a EUR 1 million safe harbour, with carryforward of denied interest. The rule replaced the former 4:1 debt-to-equity thin-capitalisation test for related-party loans. Stand-alone entities and financial undertakings are outside the scope, and arm's-length pricing of related-party interest (published recognised interest rate or documented market rate) remains a separate condition of deductibility.

2.5 Losses

Tax losses may be carried forward indefinitely, but utilisation in any year is limited to 50% of the current-year tax base, and the combined 63% relief cap in section 2.3 applies on top. There is no carryback. Loss carryforwards are forfeited where ownership of more than 50% changes and the company substantially changes or suspends its activity around the ownership change.

2.6 Group taxation

Slovenia has no consolidated group taxation regime: each company is assessed on a stand-alone basis, and group relief between Slovenian affiliates is not available. Groups therefore manage the 50% loss-offset limit and the 63% relief cap entity by entity. Intra-group transactions must satisfy transfer pricing rules, although documentation burdens between two Slovenian residents are reduced where neither party enjoys a preferential position (loss carryforwards or exemptions).

2.7 Controlled foreign companies

Under ATAD-based CFC rules, a Slovenian company that alone or with associates holds more than 50% of the capital, votes or profit rights of a low-taxed foreign entity — one whose actual corporate tax is lower than half the tax that would have been charged in Slovenia — must include the entity's non-distributed passive income (interest, royalties, dividends, financial leasing, banking and insurance income, and invoicing income from associated enterprises with little economic value added) in its tax base, unless the CFC carries on substantive economic activity supported by staff, equipment, assets and premises.

2.8 Transfer pricing

Slovenia follows the arm's-length principle in line with the OECD Transfer Pricing Guidelines, using the classic methods with a best-method approach. Related parties are defined by a 25% direct or indirect participation threshold. Contemporaneous documentation (master file and country-specific file) must be available on request; country-by-country reporting applies to groups with consolidated revenues of EUR 750 million or more, with notification duties for Slovenian constituent entities. Advance pricing agreements are available bilaterally or unilaterally through FURS, and prescribed safe-harbour interest rates are published for related-party financing.

2.9 Incentives

The flagship incentive is the 100% additional deduction for qualifying research and development expenditure, effectively doubling the deduction for in-house and contracted R&D. An investment allowance of 40% applies to investments in equipment and intangibles, and a separate 40% allowance covers investments in the digital and green transition (cloud computing, cybersecurity, decarbonisation, renewables). Employment allowances apply to hiring under-29, older, deficit-occupation and disabled workers, and further allowances cover voluntary supplementary pension contributions, donations and practical training. All allowances are subject to the combined 63% cap on reducing the tax base; unused R&D and investment allowances carry forward five years.

2.10 Pillar Two

The Minimum Tax Act (ZMD) applies the 15% global minimum tax to multinational and large-scale domestic groups with consolidated revenues of at least EUR 750 million in at least two of the preceding four financial years. Top-up tax is charged under the income inclusion rule, with the undertaxed profits rule as backstop, and a qualified domestic minimum top-up tax preserves Slovenia's primary right to tax the excess profit of Slovenian constituent entities. Transitional CbCR safe harbours and simplified calculations are available, but every in-scope constituent entity must file a GloBE information return and top-up tax calculation, with the option to appoint a designated filing entity where several group companies are located in Slovenia.

2.11 Branch income and reorganisations

A Slovenian branch (permanent establishment) of a foreign company is taxed at 22% on the profits attributable to it under arm's-length attribution principles; there is no branch profits or remittance tax, so after-tax branch profits can be repatriated without withholding. Mergers, divisions, exchanges of shares and transfers of business units can be carried out tax-neutrally under rules aligned with the EU Merger Directive, subject to advance notification to or approval by FURS, book-value continuation and preservation of Slovenian taxing rights; loss carryforwards transfer within limits. Exit taxation applies at fair market value where assets or residence leave Slovenian jurisdiction, with instalment payment over five years for EU/EEA transfers.

3.1 Residence and rates

Resident individuals are taxed on worldwide income; non-residents on Slovenian-source income. Residence follows a permanent home, habitual abode or centre of vital interests in Slovenia, or presence exceeding 183 days in a tax year. Employment, business, agricultural, rental (where not finally taxed), royalty and other income is aggregated and taxed at progressive rates in five brackets: 16%, 26%, 33%, 39% and 50%, with the top rate applying to taxable income above approximately EUR 80,000. A general allowance of approximately EUR 5,000 (indexed, and higher for low incomes) plus dependant and other personal allowances reduce the base. The annual assessment is largely pre-completed by FURS from withholding data.

3.2 Capital income and real estate

Capital income of residents is taxed at a flat, final (schedular) rate of 25%: dividends, interest and capital gains are not aggregated with other income. Capital gains taper with the holding period — 25% for holdings up to five years, 20% after five years, 15% after ten years and 0% after fifteen years — with the disposal of a principal residence held and occupied for the requisite period exempt. Interest on bank deposits with Slovenian and EU banks benefits from a EUR 1,000 annual exemption. Rental income from property is taxed at a final 25% on income reduced by 10% standardised costs (or actual maintenance costs). Property transfers attract a 2% real estate transfer tax where VAT is not charged.

3.3 Social security and payroll

Social security contributions are levied without a general ceiling: employees pay 22.10% (pension 15.50%, health 6.36%, and small unemployment and parental-protection components) and employers approximately 16.10% on gross salary, both withheld and remitted through the employer's payroll (REK) filings. A compulsory monthly health contribution of roughly EUR 37 per insured person and, from mid-2025, a long-term care contribution of 1% each for employee and employer apply in addition. Payroll withholding of income tax operates as an advance against the annual assessment. Sole traders may opt for the normirani s.p. flat-rate regime, deducting standardised expenses (up to 80% within revenue caps) in lieu of actual costs.

3.4 Inbound individuals

Slovenia has no general expatriate tax regime, but posted workers can exclude part of their remuneration under conditions, and frontier and posted-worker situations are governed by EU social security coordination and tax treaties. There is no net wealth tax; inheritance and gift tax applies at progressive rates by kinship class, with spouses and direct descendants (Class I) exempt. Individuals emigrating with substantial holdings should note that Slovenia taxes capital gains on a realisation basis with the holding-period taper rather than through a general personal exit tax, while treaty tie-breakers and the 183-day rule determine residence in split-year situations.

Slovenia levies a 15% withholding tax on outbound dividends, interest and royalties paid to non-residents, and on certain other payments: fees for consulting, marketing and similar services paid to persons in listed jurisdictions with profit-tax rates below 12.5%, payments for the lease of Slovenian real estate, and payments to entertainers and sportspersons. The EU Parent-Subsidiary and Interest-Royalties Directives eliminate withholding on qualifying intra-EU dividends (10% participation held 24 months, with a bank-guarantee option during the holding period) and on interest and royalties between 25% associated companies. Slovenia's network of roughly 60 treaties typically reduces dividend withholding to 5–15% and interest and royalties to 0–10%. Relief at source requires advance clearance on prescribed forms (KIDO); otherwise tax is withheld at 15% and refunded on application.

Withholding is due at payment and remitted by the Slovenian payer, which bears liability for under-withholding. Directive relief is conditional on beneficial ownership and anti-abuse screening; FURS scrutinises substance in intermediate holding companies before granting KIDO clearances, in line with EU case law on withholding-tax abuse. Because there is no branch remittance tax, branches repatriate free of withholding, which can make PE structures attractive for inbound operations that do not need limited liability locally.

5.1 General anti-abuse and hybrids

The Tax Procedure Act contains substance-over-form and abuse-of-law doctrines that operate as a general anti-avoidance rule, complemented by the ATAD GAAR denying arrangements whose main purpose is a tax advantage that defeats the object of the law. Hybrid mismatch rules neutralise deduction/non-inclusion and double-deduction outcomes involving hybrid instruments, hybrid entities, permanent establishment mismatches and imported mismatches by denying the deduction or forcing inclusion. The dividend exemption is refused for payments from listed low-tax jurisdictions and for instruments that are deductible for the payer.

5.2 Exit taxation and disclosure

Exit taxation applies at fair market value on transfers of assets, business or residence out of Slovenian taxing jurisdiction, with payment in instalments over five years for transfers within the EU/EEA. DAC6 mandatory disclosure applies to reportable cross-border arrangements bearing the prescribed hallmarks, DAC7 imposes platform-operator reporting, and public country-by-country reporting applies to large multinationals under the EU directive as implemented. Slovenia has ratified the multilateral instrument, so treaty benefits are subject to the principal-purpose test, and exchange of information — automatic, spontaneous and on request — follows EU and OECD standards, including CRS financial-account reporting.

6.1 VAT

VAT is levied at a standard rate of 22%, a reduced rate of 9.5% (foodstuffs, water, pharmaceuticals, passenger transport, books and similar items, admission to cultural and sporting events, residential housing within social policy) and a super-reduced 5% rate for printed and electronic books and newspapers. Registration is mandatory once taxable turnover exceeds EUR 60,000 in the preceding twelve months, with voluntary registration below the threshold and an EU-wide small-business scheme available. Returns are generally monthly (quarterly for smaller taxpayers) and due, with payment, by the last working day of the following month; recapitulative statements for intra-EU supplies are due by the 20th. Intra-EU acquisitions, reverse charge (including a domestic reverse charge for construction, scrap and real estate transactions under option) and the OSS/IOSS schemes follow the EU VAT Directive. Input VAT is recoverable for taxed activities, with a 20-year adjustment period for immovable property.

6.2 Transaction, payroll and other taxes

Real estate transfer tax of 2% applies to transfers of immovable property outside the scope of VAT, payable by the seller unless agreed otherwise. A financial services tax of 8.5% applies to fees for services exempt from VAT (mainly banking commissions), and an insurance premium tax of 8.5% applies to most non-life premiums. For 2024–2028 banks pay a 0.2% tax on total balance-sheet assets as part of flood-reconstruction financing. Owners of real estate pay the charge for the use of building land pending broader property-tax reform, and motor vehicle, excise (energy, alcohol, tobacco), environmental and CO2 levies apply. Inheritance and gift tax is levied at progressive rates by kinship class (Class I — spouses and direct descendants — exempt). There is no net wealth tax and no stamp duty of general application.

7.1 Filing, assessment and audit

The tax year for CIT is the calendar year or a deviating business year notified to FURS (fixed for at least three years). Corporate returns are filed electronically through the eDavki portal within three months of the year end — 31 March for calendar-year taxpayers — on a self-assessment basis, with advance payments for the current year set by the return and paid in monthly instalments (quarterly where the annual advance does not exceed EUR 400). Personal income tax operates through withholding and pre-completed assessments issued by FURS, with capital-income and rental returns due at the end of February for the preceding year. Audits are risk-based; the general assessment limitation period is five years from the year the tax fell due, with a ten-year absolute limit.

7.2 Rulings, appeals and penalties

Binding advance rulings on the tax treatment of intended transactions are available from FURS for a fee, alongside advance pricing agreements and KIDO clearances for treaty relief. Assessments and audit decisions may be appealed to the Ministry of Finance as second instance, then to the Administrative Court, with further recourse to the Supreme Court and, on constitutional questions, the Constitutional Court; EU-law questions can be referred to the Court of Justice. Mutual agreement procedures and the EU arbitration mechanisms address double taxation. Default interest accrues on late payment; misdemeanour fines scale with the severity of the breach and company size, and voluntary self-disclosure before discovery mitigates penalties, with a modest interest surcharge replacing fines.

Pre-completed personal assessments are issued in spring; taxpayers who receive none must self-file by 31 July. Where a company adopts a deviating business year, the three-month filing clock runs from its own year end, and advance instalments continue until reset by the next return. Balances assessed on audit bear interest from original due dates, so voluntary corrections through self-disclosure are usually cheaper than awaiting audit.

9.1 Entity choice

The d.o.o. is the standard vehicle: minimum share capital of EUR 7,500, one or more directors, incorporation possible within days through the one-stop e-VEM/SPOT system. The d.d. (minimum capital EUR 25,000) suits capital-market and regulated businesses. Partnerships (d.n.o., k.d.) are less common and generally transparent in economic effect through partner-level taxation of profit shares. Branches of foreign companies are registered at the court register and taxed at 22% on attributable profits with no remittance tax. Entrepreneurs frequently begin as s.p. sole traders — with the optional flat-rate expense regime — before converting to a d.o.o. as the business grows.

9.2 Structuring and incentives

Holding structures benefit from the 95% dividend exemption and directive-based relief on inbound and outbound intra-EU flows, though the modest 47.5% effective capital-gains exemption and the absence of group taxation distinguish Slovenia from fuller participation-exemption jurisdictions. Operating companies should maximise the 100% R&D super-deduction and the 40% investment and digital/green allowances, planning multi-year relief usage around the 63% cap and the 50% loss-offset limit. Financing structures must clear the 30% EBITDA limitation, published safe-harbour interest rates and hybrid rules together. In-scope multinationals should model the interaction of generous allowances with the 15% Pillar Two floor, as the QDMTT can claw back the benefit of a very low domestic effective rate.

9.3 Worked effective-rate illustration

A Slovenian d.o.o. earns EBITDA of EUR 2,000,000, books depreciation of EUR 300,000 and net interest expense of EUR 150,000. The interest is fully deductible (below the EUR 1 million safe harbour). Pre-relief taxable profit is 2,000,000 − 300,000 − 150,000 = EUR 1,550,000. Qualifying R&D spend of EUR 400,000 earns a 100% additional deduction of EUR 400,000, and equipment investment of EUR 500,000 earns a 40% allowance of EUR 200,000 — total reliefs of EUR 600,000, comfortably within the 63% cap (63% × 1,550,000 = EUR 976,500). The tax base is 1,550,000 − 600,000 = EUR 950,000 and CIT at 22% is EUR 209,000 — an effective rate of 209,000 / 1,550,000 = 13.5% on pre-relief profit. If the after-tax profit were fully distributed to a resident individual, the final 25% dividend tax would apply at shareholder level; ignoring reliefs, the combined statutory burden on distributed profits is 22% + (78% × 25%) = 41.5%.

9.4 Compliance

Expect fully electronic dealings with FURS via eDavki, monthly payroll and VAT cycles, annual financial statements filed with AJPES (publicly accessible), transfer pricing documentation held ready for audit, DAC6 monitoring of cross-border arrangements, and beneficial-ownership register filings. In-scope groups should budget for Pillar Two data collection, GloBE information returns and QDMTT computations for every Slovenian constituent entity even where safe harbours reduce the top-up to zero, and banks additionally for the temporary balance-sheet tax through 2028.