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Measures List
First Prev Next Last Separator
Measure Name
Date when measure came into force
Changes to the Rate and Tax reliefs 2012/01/01
Further rate decrease 2013/01/01
Loss offset limitation 2013/01/01
Rate change freeze 2014/01/01
Results 1 - 4 of 4.

Generic Tax Name Corporate income tax
Tax name in the national language Davek od dohodkov pravnih oseb (DDPO-2)
Tax name in English Corporate Income Tax
Member State SI-Slovenia
Tax in force since 2007/01/01
If abolished, date on which the tax ceases to apply
Business version date 2015/01/01
Version date 2015/02/17
This file was last updated on

Type of tax
Direct taxes Personal income tax
Corporate income tax
Other

Indirect taxes VAT
Excise duty (EU harmonised)
Alcoholic beverages
Energy products and electricity
Manufactured tobacco
Other

Social security contribution Employers
Employees
Other
 
Legal base

Corporate Income Tax Act - Zakon o davku od dohodkov pravnih oseb - ZDDPO-2
(Official Gazette of the Republic of Slovenia No.117/06, 90/07,
56/08, 76/08, 92/08, 5/09, 96/09, 43/10, 59/11, 24/12, 30/12, 94/12, 81/13, 50/14, 23/15).

 
Who sets
The tax rate is set by




The tax base is set by




The reliefs are set by




Comments
 
Beneficiary





Comments

 
Geographical Scope Republic of Slovenia.
 
Taxpayers
Domestic-source income of non-resident entities is Taxed
Not Taxed
Comments

Non – residents are liable for tax on all income originating in Slovenia.

 
Tax object and basis of assessment
As general rule, taxable income under corporate income tax includes also








Comments

Income considered Domestic income
Worldwide income (subject to double-tax relief)
Comments

Comments

Residents of Slovenia are liable for tax on all income originating in Slovenia and on all income originating outside Slovenia. Non - residents are liable for tax on all income originating in Slovenia.

A taxpayer is a resident in Slovenia if it fulfils at least one of the following conditions: it has its head office in Slovenia or its place of effective management in Slovenia. A non-resident is a taxpayer who does not fulfil none of the above mentioned conditions.

The taxable base of a resident or a non-resident in respect of activities performed in or through a business unit in Slovenia is profit determined in accordance by the Corporate Income Tax Act.

Profit is determined as a surplus of revenues over expenses recognized in the income statement according to accounting standards unless otherwise stipulated by the Corporate Income Tax Act. Taxable income includes revenues, which are determined according to accounting standards unless otherwise stipulated by the Corporate Income Tax Act. Recognized expenses according to the Corporate Income Tax Act are those expenses required to acquire taxable revenue.

The taxable base for withholding tax is every individual income.

Taxable base between linked persons is being adjusted for taxpayer's revenues/expenses for assets, including intangible assets and services whereby the revenues/expenses should not be less/more than the amount established by taking into account the prices for such assets or services or comparable assets or services that are achieved or would be achieved in comparable circumstances on market between unlinked persons. The comparable market price is being determined by one of the following methods or combination thereof: the comparable uncontrolled price method; resale price method; the cost plus method; the profit split method. 

Losses may be carried forward undefined. However, the losses cannot be used to offset more than 50% of the taxable income in any tax year. Before 2013, there was no limit to the amount of taxable income that could be set off against available losses. No loss carry back is permitted.

 
Deductions, Allowances, Credits, Exemptions
Valuation of inventory
System First-in first-out (FIFO)
Last-in first-out (LIFO)
Average cost
Specific identification (unit method)

Comments

Depreciation rules
 
Buildings
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate 3.0 %
 
Movable (tangible) assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments

Depreciation rate for movable (tangible) assets is from 10 to 50%.

Average depreciation period
Average depreciation rate 20.0 %
 
Movable fixed assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate 20.0 %
 
Intangible assets
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate 10.0 %
 
Land (if any)
System Straight-line method
Declining balance
Production method
Combination of above
Other
Not-depreciable

Comments
Average depreciation period
Average depreciation rate


Comments

Are there limits to interest deductions? Yes No
If yes:
Definition of deduction limit

Comments

In establishing expenses, interest charged on loans received from associated enterprises shall be taken into account, however, not exceeding the level of the most recently published, known or recognised interest rate at the time of approving the loan, unless the taxpayer proves that in equal or comparable circumstances he would also receive a loan at an interest rate above the recognised interest rate under this paragraph from a lender who is a non-associated enterprise.

 

In establishing the expenses of a resident relating to transactions conducted between two residents associated enterprises the tax base shall not be increased or decreased, unless one of the residents:

1. For the tax period for which revenue and expenses are established discloses an uncovered tax loss forward from previous tax periods; or

2. Pays tax at a 0% rate or at a special tax rate, lower than the general tax rate; or

3. Is exempt from paying tax under CIT.

 

See also Thin Capitalization (TC) rules.


Is there an Allowance for Corporate Equity? Yes No
If yes:
Notional rate applied for allowance

Comments

Losses
Loss carry-forward exists? Yes No
If yes:
Time limit: Indefinite
 
Size limit:
 
Loss carry-backward exists? Yes No
If yes:
Time limit: Indefinite
 
Size limit:
 

Comments

Tax losses carried forward from previous years may be used only up to 50% of the tax base.



Comments

DEDUCTIONS:

In determination of profit, the expenses required to acquire revenue that is taxable under this Act are being recognized. Expenses that are not required to acquire revenue are expenses for which, in respect of the facts and circumstances follows that:

  • they are not a direct condition for performing activities and are not a consequence of performing activities;
  • they have a private nature;
  • and they do not conform to normal business practice. 

Non-recognized expenses are:

  • income similar to dividends, including payment of hidden profit distribution
  • expenses to cover losses from previous years
  • costs relating to private life e.g. entertainment, relaxation, sport and recreation, including the pertaining VAT
  • costs for forcible collection of taxes or other levies
  • penalties pronounced by a competent authority
  • taxes paid by an entities partner as a natural person
  • deductible VAT from previous years
  • interests paid on taxes or other levies  not paid on time
  • interests paid on loans received from persons whose principal office or place of residence is in a country outside EU with nominal level of tax on profits less than 12.5%
  • donations
  • bribes and other form of pecuniary benefit given to legal and natural persons in order that a specific event might or might not occur in a manner it would otherwise not.

Adjustments or limitations imposed on recognized expenses: representation (entertainment costs and gifts with or without logo) costs and supervisory board costs are limited to 50% of their total amount.

Except in the case of loan recipients that are banks or insurance undertakings, the interest paid on loans received from a shareholder or partner who at any time during the tax period directly or indirectly owns at least 25% of the shares in the equity capital or voting rights of the taxpayer are not being recognized as a deductible expense, if at any time during the tax period the loans exceed four times the amount of the shareholder's in the taxpayer equity capital (loan surplus), unless the taxpayer can proof that he could receive the loan surplus from a non linked person (thin capitalisation rule).

Expenses linked to depreciation may not exceed the level arrived at using straight-line depreciation and the maximum annual depreciation rates:

  1. Building projects including investment property 3%
  2. Parts of building projects including parts of investment property 6%
  3. Equipment, vehicles and machinery 20%
  4. Parts of equipment and equipment for research 33.3%
  5. Computers and computer equipment 50%
  6. Long-term plantations 10%
  7. Breeding and working herds 20%
  8. Other investments 10%

Reimbursement for annual leave, long-service bonuses, severance pay at retirement, solidarity aid, reimbursement of work-related expenses such as the cost of meals during work and for transport to and from work, field allowances, separate living allowances and reimbursement of expenses for work-related travel (per diem allowances, reimbursement of transport costs, reimbursement of accommodation costs) are fully recognized.

 

ALLOWANCES:

Are in the form of deductions from tax base.

R&D allowance - a taxable person can use the reduced tax base in the amount of 100% of the amount invested (but only up to the taxable base) in research and development. Investments referred to in this paragraph are investments in:

  • Internal research and development activities of a taxable person, including the purchase of research and development equipment which is exclusively and permanently used for the research and development activities of the a taxable person;
  • Purchase of research and development services (performed by other persons, including associated enterprises, or by other public or private research organizations).

Investment allowance - a taxable person can use the reduced tax base in the amount of 40% of the amount invested in equipment or intangible assets however not exceeding the amount of the taxable base. Equipment does not include furniture and office equipment and motor vehicles except cars and buses on hybrid or electrical drive, and trucks and buses meeting the EURO VI emission requirements.

Employment allowance - if a taxpayer employs disabled persons under the act regulating the vocational rehabilitation and employment of disabled persons may claim a reduction in the taxable base in the amount of 50% of the salaries of such persons but not exceeding the amount of the taxable base, while a taxpayer that employs disabled persons with 100% physical disability or deaf persons may claim a reduction in the taxable base in the amount of 70% of the salaries of such persons but not exceeding the amount of the taxable base. If a taxpayer employs disabled persons above the prescribed quota, their disability not being a consequence of a workplace injury or occupational disease at the same employer, may claim a reduction in the taxable base in the amount of 70% of the salaries of such persons but not exceeding the amount of the taxable base.

A tax relief for employment is granted to a taxpayer that employs a person under the age of 26 or a person above the age of 55 who has been prior to employment at least six months registered as unemployed with the Employment Service of the Republic of Slovenia and has not been employed with this taxpayer or his/her associated enterprise for the last 24 months. Such taxpayer may claim a reduction of the tax base by 45% of the person’s salary, however, only up to the amount of the tax base.

If a taxpayer by a teaching agreement employs an apprentice or a student for performing practical work in a professional education, may claim a reduction in the taxable base in the amount of the salary paid, but not exceeding 20% of the average monthly salary in Slovenia for every month of performing practical work and every individual person who takes place in such professional education.

Voluntary supplementary allowance - A taxpayer employer that finances a pension plan of collective insurance and fulfils the conditions from Pension and Disability Insurance Act may claim a reduction in the taxable base for premiums for voluntary supplementary pension insurance paid in full or in part for the benefit of insured employees to a pension plan provider with a principal office in Slovenia or in an EU member state according to a pension plan approved and entered into a special register in accordance with the regulations regulating voluntary supplementary pension and disability insurance for the year in which the premiums were paid, but not exceeding an amount equal to 24% of the compulsory contributions for pension and disability insurance for an insured employee, and no more than 2,819 EUR annually, but not exceeding the amount of the taxable base for the tax period.

Donations allowance - A taxpayer may claim a reduction in the taxable base for amounts paid in cash and in kind for humanitarian, disabled, charitable, scientific, educational, medical, sports, cultural, ecological and religious purposes, for payments made to residents of Slovenia or residents who are state members of EU or EEA (however excluding the Principality of Liechtenstein) and are established under special regulations for performance of such activities and up to an amount equivalent to 0.3% of the taxpayer’s taxable revenue in the current tax period. A taxpayer may also claim a reduction in the taxable base for amounts paid in cash and in kind to political parties and representative trade unions up to an amount equivalent to three times the average monthly salary per employee of the taxpayer in the current tax period. The cumulative total of allowances may not exceed the amount of the taxable base.

There is an additional reduction of 0.2% of the taxpayer’s taxable revenue for amounts paid in cash and in kind for cultural purposes and voluntary societies incorporated for protection from natural in other disasters, who work in public interest and are residents of Slovenia or residents of state members of EU or EEA (however excluding the Principality of Liechtenstein) and are established under special regulations for performance of such activities.

 

TAX CREDITS:

There is a system for avoiding legal double taxation: from the tax liability under the tax return for an individual tax period, a resident of Slovenia may deduct an amount equal to the relevant tax on income from sources outside Slovenia (foreign tax) paid thereby under this Act on income from sources outside Slovenia (worldwide income) included in its taxable base. The tax credit may not exceed:

  • the lower of the amount of foreign tax on foreign income that was final and actually paid or
  • the amount of tax that would be payable under this Act in respect of foreign income had the tax credit not been allowed.

 

EXEMPTIONS:

There are a limited number of legal persons who are exempt from corporate tax for income derived from non-profit activities, for example: institutes, societies, foundations, religious communities, political parties, chambers or representative trade unions.

When calculating the tax base the taxpayer may exempt received dividends and other similar income except hidden reserves (hidden reserves are calculated as a difference between fair value and tax value of assets and liabilities on the day before the entry of winding up in the court register) if the payer is:

  • liable to pay tax by the Corporate Income Tax Act or
  • is a resident of an EU member state for tax purposes in accordance with the law of such member state and is not deemed to be a resident outside the EU in accordance with an international treaty on the avoidance of double taxation concluded with a non-member state; and is a taxpayer subject to one of the taxes in connection with which the common system of taxation applying to parent companies and subsidiaries from different EU member states, whereby a company that is exempt from tax or that has the possibility of a choice of taxation should not be deemed to be a taxpayer.
  • liable to pay tax, comparable with tax according in this Act and is not a resident of a country, or in the case of a business unit not situated in a country in which the general, average, nominal level of tax on corporate profits is less than 12.5%.

If a taxpayer makes capital gain from expropriation in holdings in legal entities he may claim an exemption in the amount of 50% of realised capital gain from the taxable base if the taxpayer participated in stock or management in such way that he is the owner of shares, stock or voting rights in the amount of at least 8 % and for at least six months and has at least one person employed at full-time basis. The loss of expropriation in holdings from the previous paragraph is not recognized in the amount of 50% of its loss.

In the determination of the taxable base under the aforementioned regime of exemption of capital gains and dividends, expenses relating to participation are not recognized in the amount which is equal to 5% of received dividends and capital gain in that tax period.

A venture capital company which has been set up by the Venture Capital Companies Act  payes a corporate income tax at a rate of 0% on activities of allowed investments of venture capital in accordance with the Venture Capital Companies Act if the venture company submits a separate tax return just for that part of its activity.

A resident or non-resident taxpayer that performs an activity or business in or through a permanent establishment in Slovenia will be allowed to exclude all the profit from expropriation of capital holdings acquired by investing in a venture capital company if:

  • the venture capital company is set up in accordance with the Venture Capital Companies Act; and
  • the status of the venture capital company does not change throughout the period of owning the aforementioned capital holdings.

The loss from the abovementioned expropriation will not be recognised for tax purposes.

 
Rate(s) Structure
Nominal corporate income tax rate Rate: 17.00 %

Central government surcharge Rate:
Regional government surcharge Rate:
Local government surcharge Rate:
Combined rate (all-in rate) Rate: 17.00 %


Comments

The rate for withholding tax is 15%. With the exception of dividends and similar income distributed through a business unit of a non-resident situated in Slovenia, tax is being calculated on the income of residents and non residents originating in Slovenia. The tax is imposed on the following income:

1. dividends:

  • dividends, as profit or surplus of revenues over expenses, paid to the shareholders or members with reference to the share in profit of the payer;
  • income similar to dividends (profit paid in connection with securities and loans that ensure a share in the profits of the payer; profit, profit reserve, capital formed as increase of previous profit or reserve from profit and payer's hidden reserve; the value of shares or holdings paid decreased for their emission value and for the proportional part of capital reserves in the event of exclusion or withdrawal of shareholder, partner or member of payer; a reduction in the payer's nominal capital in part formed from the previous increase of nominal capital by profit or profit reservations; payment value of acquired stock or own shares reduced for their emission value and proportional part of stock reserve; profit transferred on the basis of a commercial contract in accordance with the act regulating commercial companies; hidden payment of profit made to the person who directly or indirectly owns at least 25% payer's value or number of shares or holdings in stock, management or supervision or masters the payer on the basis of a contract or in a manner different as it would be between non – linked persons)

2. interests, with exception of interests:

  • on loans raised by and securities issued by Republic of Slovenia and interests paid by banks;

3. payments for use of or right to use copyrights, patents, licences, trademarks and other property rights and similar income,

4. rental payments for real estate located in Slovenia,

5. payments for services of contractors or sportspersons, if such pertain to another person,

6. payments for services, if the services are performed to the entity with its head office or its place of effective management in the states where the nominal corporate tax rate is lower than 12.5% and those states are not members of the EU.

 

No tax is being withheld on income listed above when paid to:

  • Republic of Slovenia or a local authority in Slovenia
  • the Bank of Slovenia
  • a resident taxpayer that notifies the payer of its tax number
  • a non-resident taxpayer that is liable for tax on income realised through business activities in or through a business unit in Slovenia and that notifies the payer of its tax number, in case of income paid to this business unit.

The Directive on a common system of taxation applicable in the case of parent companies and subsidiaries of different Member States and The Directive on the common system of taxation applicable to interest and royalty payments made between associated companies of different Member States have been implemented.

Exemption from the withholding tax for dividends paid to recipient resident in other Member States and/or in EEA (if there is exchange of information) is granted provided that the withholding tax cannot be credited in the recipient's residence state. And no withholding tax is levied on dividends and interest paid to pension funds and  investment funds - resident in other Member States and/or in EEA (if there is exchange of information) provided that the withholding tax cannot be credited in the recipient's residence state.


Special tax rate for SMEs
Special tax rates apply to SMEs: Yes No
If yes:
Nominal corporate income tax rate Rate: 17.00 %
Central government surcharge Rate:
Regional government surcharge Rate:
Local government surcharge Rate:
Combined rate (all-in rate) Rate: 17.00 %


Comments

SPECIAL TAX BASE ASSESSMENT SCHEME BY TAKING INTO ACCOUNT NORMALISED EXPENSES

Under certain conditions taxpayers whose annual income determined in accordance with accounting principles does not exceed 100,000 EUR may opt to calculate their tax base by applying a lump-sum expense deduction. The tax base assessment shall include revenues recognised for tax purposes and lump-sum expenses amounting to 80% of these revenues. Under this scheme no tax reliefs can be claimed or tax loss declared.

 
International aspects
Treaty countries Non-treaty countries
 
Repatriated profits are taxed according to the following system Exemption system Exemption system
Tax credit Tax credit
Deduction Deduction
 
Interest received is taxed Yes No Yes No
Tax rate on interest received 17.00 % 17.00 %
Outgoing dividends withholding tax 15.00 %
Outgoing interest payments withholding tax 15.00 %
 
Foreign losses can be set-off Yes No Yes No
If yes:
Minimum direct or indirect shareholding to qualify loss-offset (if applicable)
 
Loss carry-forward exists? Yes No Yes No
If yes:
Time limit: Indefinite
 
Indefinite
 
Size limit:
 
Loss carry-backward exists? Yes No Yes No
If yes:
Time limit: Indefinite
 
Indefinite
 
Size limit:
 
Controlled foreign company (CFC-)rules exist? Yes No Yes No
If yes:
Time limit: Indefinite
 
Indefinite
 
Size limit:
 
Threshold for capital or voting power held directly or indirectly by resident in non-resident company
CFC-rules apply if foreign tax rate is lower than
CFC-rules apply for passive income only? Yes No Yes No

Comments   Treaty countries

Outgoing dividend and interest withholding tax depends on relevant treaty.


Comments   Non-treaty countries
 
Measures against profit shifting
 
Do Thin Capitalization (TC) rules exist? Yes No
If yes:
Date of first introduction
2005/01/01
Introduced as Explicit TC law
Part of CIT law
Test for TC Ratio
Arm's length
If ratio
Value of numerical ratio: 1 : 4
Definition numerator
Definition denominator Equity
 
Debt considered for test Internal
Internal and external
TC depends on shareholding? Yes No
Substantial shareholding threshold 25.00 %
 
Type of shareholding Direct
Indirect
Automatic remedy Yes No
Remedy Non-deductibility of interest
Reclassification as dividend
 
Rules apply to All companies
Foreign companies
Non-EU companies
Transfer pricing rules exists? Yes No
If yes:
Arm’s length principle applied? Yes No
 
Remedy Fee
Tax base increase
 
Tax due date

Corporate income tax is payable for the tax period, corresponding the calendar year; however, corporate taxpayers may choose a tax period to be the same as a business year which does not necessarily correspond to the calendar year. In that case the taxpayer must notify the tax authority of its choice and keep in mind that tax period chosen may not exceed a period of 12 months. The taxpayer may not change the tax period for three years.

 

Tax returns must be submitted to the tax authorities by 31 March (within 3 months) of the current calendar year for the preceding calendar year if the calendar year is the same as the tax (business) year. If the calendar year is not the same as the tax (business) year, tax returns must be submitted to the tax authorities within 3 months of the current business year for the preceding business year.

 
Tax collector

The tax collector is the Financial Administration of the Republic of Slovenia (Finančna uprava Republike Slovenije - FURS).

 
Special features

 
Economic function







Comments
 
Environmental taxes



Comments
 
Tax revenue
ESA95 code d51b

Year
Annual tax revenue (millions)
Currency
Tax revenue as % of GDP
Tax revenue as % of total tax revenue
2012 446.20 EUR 1.24
2011 610.80 EUR 1.66
2010 668.00 EUR 1.84
2009 652.00 EUR 1.80
2008 935.80 EUR 2.47
2007 1,116.30 EUR 3.18
2006 920.00 EUR 2.92
2005 794.50 EUR 2.72
2004 522.90 EUR 1.89
2003 437.10 EUR 1.66
2002 362.80 EUR 1.45
2001 261.00 EUR 1.12
2000 215.70 EUR 0.98
1999 195.80 EUR 0.92
1998 149.60 EUR 0.76
1997 138.90 EUR 0.76
1996 108.10 EUR 0.64
1995 53.80 EUR 0.33

Comments