Direct taxes - Corporate Income Tax

    Generic part

    Corporate income tax
    Davek od dohodkov pravnih oseb (DDPO-2)
    SI - Slovenia
    EUR
    Date
    Year
    2007/01/01
    2019/01/01
    2019/02/11 16:03:47

    Contact information

    Administration

    Service

    Website

    E-mail

    Telephone

    Who sets

    The tax rate is set by

    • Central authority
    • Regional authority
    • Local authority
    • Social security

    The tax base is set by

    • Central authority
    • Regional authority
    • Local authority
    • Social security

    The reliefs are set by

    • Central authority
    • Regional authority
    • Local authority
    • Social security

    Beneficiary

    • Central authority
    • Regional authority
    • Local authority
    • Social security
    • Others

    Geographical Scope

    SI - Slovenia
    No Yes

    Taxpayers

    Which entities are liable for CIT?

    • Legal persons
    • Organizational units having no legal personality
    • Tax capital groups
    • Associations
    • Foundations
    • Companies having their seat or management office in other countries, provided that in their country they are treated as legal persons and are subject to tax on income
    • Public corporations
    • Others

    Which entities are exempt from CIT?

    The Republic of Slovenia and local authorities are not taxpayers. The Bank of Slovenia does not asses and pay tax.

    Domestic-source income of non-resident entities is

    Taxed
    Not Taxed

    Tax object and basis of assessment

    As general rule, taxable income under corporate income tax includes also

    • Interest
    • Royalties
    • Dividends
    • Capital gains
    • Income from immovable property
    • Income from movable property not listed above
    • Income from agriculture

    Income considered

    Domestic income
    Worldwide income (subject to double-tax relief)

    Deductions, allowances, credits, exemptions

    Valuation of inventory

    • First-in first-out (FIFO)
    • Last-in first-out (LIFO)
    • Average cost
    • Specific identification

    Depreciation rules

    Buildings

    Depreciable
    Not-depreciable
    • Straight-line method
    • Declining balance
    • Production method
    • Combination of above
    • Other
    33 Years
    3 %

    Other fixed immovable assets (e.g. machinery)

    Depreciable
    Not-depreciable
    • Straight-line method
    • Declining balance
    • Production method
    • Combination of above
    • Other
    5 Years
    20 %

    Movable (tangible) assets (e.g. cars, furniture, work equipment)

    Depreciable
    Not-depreciable
    • Straight-line method
    • Declining balance
    • Production method
    • Combination of above
    • Other
    5 Years
    20 %

    Intangible assets (e.g. patents)

    Depreciable
    Not-depreciable
    • Straight-line method
    • Declining balance
    • Production method
    • Combination of above
    • Other
    10 Years
    10 %

    Land (if any)

    Depreciable
    Not-depreciable
    • Straight-line method
    • Declining balance
    • Production method
    • Combination of above
    • Other

    Are there limits to interest deductions (other than thin capital rules)?

    No Yes

    Is there an Allowance for Corporate Equity?

    No Yes

    Exemptions from taxable income

    No Yes
    • Income from participations (dividends)
    • Patents income (e.g. patent boxes)
    • Other, please describe
    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.

    Expenses that are generally not deductible:

    Income similar to dividends, expenses to cover losses from previous years; costs relating to private life; penalties imposed by the responsible authority; taxes paid by a partner as an individual; deductable VAT from previous years; interest a) On late payment of taxes or other levies; b) On loans received from persons whose registered office or place of actual activities of management or place of residence is in states; donations; bribes and other types of
    pecuniary benefits

    Losses

    Loss carry-forward exists?

    No Yes
    • Indefinite

    Loss carry-backward exists?

    No Yes
    • Indefinite

    Tax credits available?

    No Yes
    • For research and development investments
    • For training
    • Other, please describe:
    Employment, voluntary supplementary, donations

    Rate(s) Structure

    19 %
    19 %

    Special tax rate for SMEs

    No Yes
    19 %
    19 %

    Measures against profit shifting

    Do Thin Capitalization (TC) rules exist?

    No Yes
    2005/01/01
    • Explicit TC law
    • Part of CIT law
    • Arm’s length
    • Ratio
    1 : 4
    the amount of the shareholder or partner in the capital of the taxpayer
    capital of the taxpayer
    Internal
    Internal and external

    TC depends on shareholding?

    No Yes
    25 %
    Direct
    Indirect

    Automatic remedy

    No Yes
    • Non-deductibility of interest
    • Reclassification as dividend
    All companies
    Foreign companies
    Non-EU companies

    Transfer pricing rules exists?

    No Yes
    No Yes
    • Fee
    • Tax base increase

    Special features

    Is group taxation available?

    No Yes

    Is there a specific anti-avoidance provision in the legislation?

    No Yes

    International aspects

     
    Treaty countries
    Non-treaty countries
    Repatriated profits are taxed according to the following system
    • Exemption system
    • Tax credit
    • Deduction
    • Exemption system
    • Tax credit
    • Deduction
    Interest received is taxed
    No Yes
    No Yes
    Tax rate on interest received
    19 %
    19 %
    Outgoing dividends withholding tax
    5 %
    15 %
    Outgoing royalty payments withholding tax
    5 %
    15 %
    Outgoing interest payments withholding tax
    5 %
    15 %
    Foreign losses (of either subsidiaries or permanent establishments) can be set-off
    No Yes
    No Yes
    If yes :
    Minimum direct or indirect shareholding to qualify loss-offset (if applicable)
    Loss carry-forward exists?
    No Yes
    No Yes
    If yes :
    Time limit
    • Indefinite
    • Indefinite
    Size limit
    Loss carry-backward exists?
    No Yes
    No Yes
    If yes :
    Time limit
    • Indefinite
    • Indefinite
    Size limit
    Controlled foreign company (CFC-) rules exist?
    No Yes
    No Yes
    If yes :
    Time limit:
    • Indefinite
    • Indefinite
    Size limit
    Threshold for capital or voting power held directly or indirectly by resident in non-resident company:
    50 %
    50 %
    CFC-rules apply if foreign tax rate is lower than:
    9.5 %
    9.5 %
    CFC-rules apply for passive income only?
    No Yes
    No Yes

    Tax due date

    When has the tax return to be filed

    • 3 months after closing of the tax period
    • 6 months after closing of the tax period
    • Later than 6 months after closing of the tax period
    • Date set by the Authority
    • Other
    • Extensions of the deadline are possible

    Advance tax payments due?

    No Yes
    • Monthly
    • Quarterly
    • Bi-annual
    • Annual
    • Other

    Tax collector

    General comments

    Economic function

    • Consumption
    • Labour Employed (paid by employers and employees)
    • Labour Non-employed
    • Capital income: corporations
    • Capital income: income of households
    • Capital income: income of self-employed
    • Capital stocks

    Environmental taxes

    • Energy
    • Transport
    • Pollution/resources

    Tax revenue

    d51b
    Year Annual tax revenue (in millions) % of GDP % of total tax revenue -
    2017
    763.8
    1.7763 %
    4.8675 %
    2016
    645
    1.5982 %
    4.3503 %
    2015
    568
    1.4615 %
    3.9967 %
    2014
    528.7
    1.406 %
    3.8575 %
    2013
    433.2
    1.1954 %
    3.2596 %
    2012
    446.2
    1.2368 %
    3.3381 %
    2011
    610.8
    1.6555 %
    4.5113 %
    2010
    668
    1.8426 %
    4.9618 %
    2009
    652
    1.8028 %
    4.9464 %
    2008
    935.8
    2.4658 %
    6.7379 %
    2007
    1,116.3
    3.1756 %
    8.5673 %
    2006
    920
    2.915 %
    7.7431 %
    2005
    794.5
    2.7176 %
    7.1605 %
    2004
    522.9
    1.8852 %
    5.0364 %
    2003
    437.1
    1.6618 %
    4.4509 %
    2002
    362.8
    1.4483 %
    3.8971 %
    2001
    261
    1.1227 %
    3.0489 %
    2000
    215.7
    0.9839 %
    2.6861 %
    1999
    195.8
    0.9233 %
    2.4761 %
    1998
    149.6
    0.7569 %
    2.0497 %
    1997
    138.9
    0.7587 %
    2.0989 %
    1996
    108.1
    0.6387 %
    1.7152 %
    1995
    53.8
    0.3305 %
    0.8615 %

    Footnotes