Page 50 - CEE Tax Guide 2024

Slovenia VAT and other indirect taxes or electronic forms. EC Sales lists (IC report) are obligatory
in Slovenia. For cross-border sales to consumers,
The general tax rate is 22%; a reduced rate of 9.5% a threshold of EUR 10,000 is applied in Slovenia.
applies to some goods, e.g., food, water supply, carriage Electronically supplied services to consumers worth less
of passengers and their personal luggage, and a reduced than EUR 10,000 are subject to Slovenian VAT rules.
rate of 5% applies to books and newspapers, regardless
Mazars Consulting d.o.o. of whether they are delivered on physical media Personal income tax / Social security system
Verovškova ulica 55A
1000 Ljubljana, VAT options in Personal income tax rates are progressive (16%, 26%,
Slovenia Slovenia Applicable / limits 33%, 39% and 50%), and apply on active income sources
Phone: +386 59 049 500 (employment, business income, agriculture and forestry,
www.mazars.si EUR 10,000/year other income). Capital and rental income is taxed at a flat
Distance selling The OSS system is applicable from rate (dividends at 25%, interest at 25%, capital gains from
July 1, 2021.
Call-off stock ü 0% to 25% – depending on the holding period, rental
income at 25%.
VAT group registration No Social security contributions are applicable on income from
Corporate taxes and other direct taxes supplementary pension insurance. From 2022 a new tax Cash accounting – yearly EUR 400,000/year employment and are 16.10% for the employer and 22.10%
amount in EUR (approx.)
allowance for investment in the digital & green transition for the employee. From the January 2024 onwards there
Temporary increase of CIT rate (1.1. 2024 until 31.12. 2028) was introduced. Provisions governing the GAAR & CFC Yes, special treatment for tax non- is also a separate flat EUR 35 monthly fee for mandatory
to 22% (before 19%). The tax base is the accounting profit as a part of the EU ATAD I are applicable from 2019. residents with use of Slovene VAT medical insurance. Self-employed individuals (business
modified by increases & decreases. Slovenia uses thin capitalization (4:1), but doesn't apply Import VAT deferment ID number, simplification can be used income) pay their own social security contributions
only in case where they appoint tax
Losses can be carried forward without limitations & can if shareholders are financial institutions & the taxpayer representative who is also jointly depending on the circumstances of the case. There are
be used only up to 50% of the tax base. Special rules provides evidence of such possible loan surplus from liable for VAT. a number of personal allowances that apply individually
apply in case of M&A transactions. Tax allowances are a lender that is a non-associated enterprise. Construction works and supply of staff depending on the personal status of the individual.
available for new investments, R&D, new employments, the The amendments to CIT Act (effective from 2024), further Local reverse charge in relation to construction works, supply
of immovable property (limited), supply
employment of disabled persons, donations & voluntary of waste and used material based
restrict business between related companies (in line with on specifications, transfer of greenhouse
Transfer pricing in Slovenia the interest limit in the ATAD Directive). The amendments gas emission allowances.
regulate the rule on recognition of interest for tax purposes Option for taxation
Since 2005 in Article 16 of the
Arm’s length principle ü Slovene Corporate Income (i.e. EBITDA rule). The limitation regulates deductubility letting of real estate ü
Tax Act (CITA). of interest for tax purposes for loans between related
Slovene Ministry companies (recognized as an income up to higher of (1) supply of used real estate ü
Documentation liability ü of Finance issued regulations 30% of taxpayer's EBITDA, (2) EUR 1 mio). VAT registration
on TP on 1 January 2007. threshold EUR 50,000/year
APA ü Available In addition, the amendments relate to provisions
Country-by-Country concerning the determination of a non-resident's PE & non
liability ü Since 2016 resident's place of business not determined as PE. The most
Master file-local file significant change relates to provisions governing the place
(OECD BEPS 13) ü Since 2006 of business of a non-resident that is considered PE, as they
applicable do not apply to a place of business used or maintained Average wage
Penalty by a non-resident who is closely related to another non- Wage related taxes in Slovenia Minimum wage in private sector
Penalty is EUR 1,200 to EUR resident or resident & if that person carries out business
30,000 depending of the size
lack of documentation ü of the legal entity and up to EUR activities at the same or another place in Slovenia & those in EUR in EUR
4,000 for the responsible person. business activities are part of an overall business. 1,253 2,348
30% of underpaid tax for Withholding tax of 15% is applied on dividends,
micro and small legal entities interest, royalties and rental income paid by a Slovenian Total wage cost 1,456 116.10% 2,726 116.10%
(underpaid tax from EUR 1,500 to Employer's contribution** 202 16.10% 378 16.10%
EUR 150,000). 45% of underpaid company to a foreign company. However, if conditions
tax shortage ü tax for medium and large are met, an exemption (or decrease in the percentage Gross salary 1,254 100.00% 2,348 100.00%
companies (underpaid tax from
EUR 2,000 to EUR 300,000). of withholding tax) is applicable to payments Employees' contributions** 312 22.1%+EUR 35 554 22.1% + EUR 35
Responsible person up to to EU residents (under the Parent Subsidiary Directive
EUR 5,000. & the interest and royalty directive or under local WHT Tax and surtax* 84 6.70% 285 12.15%
Related parties ü exemption), and under international Double Taxation Net salary 858 68.43% 1,509 64.26%
– Administratively determined Treaties (there are currently over 60 treaties). * Tax base differs from the gross salary, deductions apply.
recognized interest rate for all ** In the case of a minimum wage, a higher calculation base must be used to calculate social security contributions.
loans between RPs. • Real estate transfer tax (RETT) is applied on the transfer ** Latest available information about average wages in the private sector is December 2023. In 2024 we should expect a drop in average net salaries due to the new EUR 35 monthly flat
– For interest rates in line with the fee for mandatory medical insurance.
government regulations the thin of immovable property at the rate of 2% if transaction
cap 1:4 ratio applies. is not subject to VAT where the tax base is selling price.
– The rule limiting the recognition
Safe harbors ü of interest for tax purposes for • DAC7 obligatory reporting from period 2023 onwards -
loans between RPs within a group with first reporting due date on 31 January 2024.
(new in 2024 EBITDA rule).
– Safe harbor rule applicable • On 13 December 2023, the Minimum Tax Act Teja Paulin
between domestic RPs, only was adopted. In brief, the new act will introduce
if RPs involved in domestic IC Tax Partner
transactions are in different tax an additional tax liability from 2024 onwards for groups Phone: +386 59 049 500
positions. whose annual revenue on consolidated level in at least
Level of attention paid by Tax two of the last four financial years amounts to 750 Mobile: +386 40 534 522
Authority 9/10 million EUR or more. E-mail: teja.paulin@mazars.si

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