Slovenia country profile - 2020

Slovenia country profile - 2020

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

business people standing in a modern courtyard

EU Member State


Double Tax Treaties

With the following countries, territories and jurisdictions:

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


Notes: (a) Treaty signed 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


Registration duties


Transfer duties

On the transfer of shares


On the transfer of land and buildings

2 percent Real Estate Transfer Tax.

Stamp duties


Real estate taxes


Controlled Foreign Company rules


Transfer pricing rules

General transfer pricing rules


Documentation requirement


Thin capitalization rules

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

General Anti-Avoidance rules (GAAR)


Specific Anti-Avoidance rules/Anti Treaty Shopping Provisions/Anti-Hybrid rules

Principle "substance over form" - Tax Procedure Act.

Advance Ruling system

Binding rulings may be obtained before the intended transaction is undertaken. With regard to transfer pricing, unilateral, bilateral or multilateral Advanced Pricing Agreements can be concluded.

IP / R&D incentives


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.


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

Other relevant points of attention



Source: Slovenian tax law and local tax administration guidelines, updated 2020.

Mandatory Disclosure Rules Updates

For country specific information and updates on the EU Mandatory Disclosure Rules please visit KPMG’s EU Tax Centre’s MDR Updates page.

COVID-19 Resources

An overview of tax developments being reported globally by KPMG member firms in response to the Novel Coronavirus (COVID-19) is available here. For further insight into the potential tax, legal and mobility implications of COVID-19, please refer to the dedicated KPMG page.

Contact us

Mehle Marko

KPMG in Slovenia

T: +38614201153


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