Last reviewed 18 Apr 2024
All legal persons, both limited liability companies and limited partnerships and cooperatives, as well as other legal entities (e.g., public-law institutions, foundations) are subject to corporate income tax.
22 %
Corporations resident or managed in Slovenia
Foreign corporations neither resident nor managed in Slovenia, on their Slovenian income
Slovenian public sector institutions, on their taxable income and/or income from commercial operations
Calendar year; alternative fiscal year possible, must be reported to tax office and retained for three years
Without exception, double-entry bookkeeping in accordance with Slovenian accounting standards. It is mandatory to use the standard chart of accounts. Stock exchange listed companies, banks and insurance companies are obliged to use IFRS. Other companies may use IFRS accounting principles if a shareholders' resolution to that effect exists.
no loss carryback
Tax losses carried forward can be utilized only up to 50% of the tax base.
Where purchase of a shell company with tax losses is assumed (change in ownership of at least 50 % and material changes in the company’s business activities, or no business activities in the last 2 years), tax losses are forfeited. Exceptions for prevention of unemployment.
Necessary expenses of the business. Commercial law also applies to tax law unless otherwise stipulated by mandatory tax regulations.
Arm’s length principle based on OECD transfer price regulations
tax deductibility applies
Statutory maximum (section 32 ZDDPO): interest on loans from associated parties is only deductible for tax purposes where the debt / equity ratio is not lower than 4:1. This thin capitalisation provision is not applicable if the taxable party is able to prove that this financing could also have been obtained from an unrelated third party (offer of loan from unrelated third party). Financing by non-related parties, for which the shareholder is liable, is equivalent to financing by shareholders; e.g. also pledging of shares.
The statutory debt / equity ratio applies without exception from 2012. Since 2014 equity is calculated as average of all equity-positions of the financial year except yearly profits. Loss carryforwards and financing of sister-companies are also to consider.
Interest on shareholder loans exceeding the permissible debt / equity ratio is not tax deductible. In addition to this thin capitalisation restriction, the interest ceilings (maximum deductible interest amounts) for shareholder loans as described above (see “Operating expenses”) must be taken into account.
Maximum depreciation rates for tax purposes are as follows:
Buildings 3 %
Building parts: 6 %
Plant, equipment and vehicles 20 %
Equipment parts and research equipment 33 %
Computers, software 50 %
Perennial plantations 10 %
Breeding herds 20 %
Other intangible fixed assets and built-in components in third party property 10 %
Statutory depreciation for financial accounting purposes (straight-line, reducing balance, etc.) must also be used for tax purposes provided the maximum rates above are not exceeded.
Provisions for guarantees, reorganisation, contingent losses, long-service bonuses, pensions, and separation indemnities are only 50% tax deductible. Provisions required under special laws for banks, insurance companies, and securities brokerage firms are tax deductible to the extent legally required. Liabilities of uncertain amount (e.g. costs of annual financial statements preparation, audit costs) are recognised as other liabilities (as accrued liabilities under Slovenian accounting rules) and are deductible.
Provisions for long-service bonuses, pensions, and separation indemnities are only 100% tax deductible in period from 1 January 2022 to 31
December 2026.
Depreciation over at least five years.
No limitation as to amount (adequacy of acquisition cost).
Only 50% of entertainment expenses are allowable for tax purposes. Hospitality expenses and gifts to business partners are deemed to be entertainment expenses.
Bribes, whether in cash or in kind.
Certain charitable donations: however, provided there is a taxable profit, they are deductible as special allowances up to a certain ceiling. Additionally, donations are only deductible for the EU/EEA (except Liechtenstein). Charitable donations are deductible. Since 01.01.2017 political donations are not deductible, as they are not permitted by law.
Personal taxes and input VAT, disregarded although deductible.
Remuneration of supervisory board members: 50 %.
Expenses directly relating to non-taxable income and expenses not associated with any revenues.
5 % of expenses relating to tax-free dividend income is not tax deductible.
Interest on loans from low-tax countries (except EU countries) are not tax deductible. Low-tax countries are those with corporate income tax rates of less than 12.5 %. The Finance Ministry publishes a list of low-tax countries.
Interest is limited at the tax-approved rate and thin capitalisation. From 1 January 2024 the EBITDA limitation rule applies.
In the case of interest from affiliated companies, tax-recognized interest rates based on EURIBOR or other reference rates (for other loan currencies), or on market rates, must be observed. EURIBOR or other reference rates are adjusted to include maturity and credit rating premiums. For variable interest agreements the respective monthly, 3 months’, 6 months’ or 12 months’ EURIBOR is applied. The interest rate applicable at the time of lending is applied for the whole term of the loan only in the case of fixed interest agreements. The reference interest rate (EURIBOR) constitutes the ceiling for expenses and the floor for income. The interest rate applied for tax purposes is generally EURIBOR plus 1 %. Where it can be shown that the market interest rate is higher or lower than the rate recognised for tax purposes, the market interest rate will constitute the interest ceiling or interest floor for tax purposes.
Interest rates effective for tax purposes are only applicable to interest payments between Slovenian corporate income tax subjects with unlimited tax liability if one of the taxable parties:
In the case of persons with limited liability to taxation in Slovenia withholding tax is deducted, generally at 15 %. A lower rate may be provided in the applicable DTA resp. the Parent Subsidiary Directive.
Relief is by refund or deduction at source. With- holding tax needs to be paid within five days following the day all criterias are met. Tax related reports need to be done on the day all criterias are met.
At 15 %, or per applicable DTA and applying the EU Interest and Royalty Directive for group purposes (minimum 25 % share held for at least 24 months). Exceptions apply to banks.
At 15 %, or per applicable DTA and applying the EU Interest and Royalty Directive for group purposes (minimum 25 % share held for at least 24 months).
At 15 %, or per applicable DTA and applying the EU Parent Subsidiary Directive for group purposes (10 % holding, and holding period 24 months).
Various expenses are partially or wholly disallowed for tax purposes and increase the taxable base: *
Only 50% of entertainment expenses are allowable for tax purposes. Hospitality expenses and gifts to business partners are deemed to be entertainment expenses.
Bribes, whether in cash or in kind.
Certain charitable donations: however, provided there is a taxable profit, they are deductible
as special allowances up to a certain ceiling. Additionally, donations are only deductible for the EU/EEA (except Liechtenstein). Charitable donations are deductible. Since 01.01.2017 political donations are not deductible, as they are not permitted by law.
Personal taxes and input VAT, disregarded although deductible.
Remuneration of supervisory board members: 50 %.
Expenses directly relating to non-taxable income and expenses not associated with any revenues.
5 % of expenses relating to tax-free dividend income is not tax deductible.
Interest on loans from low-tax countries (except EU countries) are not tax deductible. Low-tax countries are those with corporate income tax rates of less than 12.5 %. The Finance Ministry publishes a list of low-tax countries.
a) Non-acceptance of purely tax-motivated actions of the taxpayer
b) Taxation of income (interest, dividends, rental income, licences, financial services, etc.) of foreign companies at the level of the Slowenian corporation. Foreign losses must not be con- sidered. Paid taxes can be credited against tax debts.
c) Determination of rules to eliminate or rather neutralize the effects of hybrid mismatch arrangements which arise from cross-border tax arrangements.
Investment income is generally tax-exempt for the recipient. Expenses in connection with tax-exempt investment income are not deductible to the extent of 5% of the tax-exempt investment income.
This is implemented by adding 5% of the investment income to the corporate income tax return. Special rules exist for profit shares of alternative investment funds.
Income from international investments is tax-exempt in Slovenia unless it originates from low-tax countries.
The provisions of the Parent Subsidiary Directive have been implemented accordingly. Dividends from low-tax countries are excluded from the investment income exemption.
Applicability, limitation of current value write-downs
No pooling in Slovenia
not applicable
not applicable
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Opening Hours:
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Opening Hours:
Mo-Th: 08:00 – 17:00
Fr: 08:00 – 14:00
