Tax Law in Slovenia

The primary legislation governing taxation in Slovenia includes the Tax Procedure Act (Zakon o davčnem postopku - ZDavP-2), Corporate Income Tax Act (Zakon o davku od dohodkov pravnih oseb - ZDDPO-2), Personal Income Tax Act (Zakon o dohodnini - ZDoh-2), and Value-Added Tax Act (Zakon o davku na dodano vrednost - ZDDV-1). These statutes establish the principles of tax liability, taxable base, rates, filing obligations, and enforcement mechanisms. The legislation is supplemented by bylaws, FURS guidelines, EU directives, and bilateral treaties.

CIT in Slovenia applies a standard rate of 19% on the worldwide income of resident companies and on Slovenian-source income of non-residents. Specific provisions address deductible expenses, tax depreciation, related-party transactions, and loss carryforwards. Compliance requires annual tax returns submission with detailed disclosures as prescribed under ZDDPO-2 and related implementing acts.

PIT in Slovenia is progressive and applies to income derived from employment, self-employment, capital, and other sources. Tax residency criteria, governed by ZDoh-2, determine the scope of taxable income. The Act provides for various allowances, exemptions, and tax credits, ensuring an equitable tax burden consistent with EU standards.

VAT is imposed at a general rate of 22%, with reduced rates on select goods and services, in line with EU VAT Directive 2006/112/EC. Taxable persons must register for VAT, issue compliant invoices, and submit periodic VAT returns. The ZDDV-1 governs the VAT base, exemptions, input tax deductions, and cross-border transaction rules.

The Financial Administration of the Republic of Slovenia (FURS) oversees tax collection, audits, compliance monitoring, and dispute resolution. The Tax Procedure Act (ZDavP-2) prescribes procedural rules, including assessment timelines, tax audits, appeals, penalties, and enforcement powers. Taxpayers have rights to appeal decisions to the Tax Chamber and subsequently to administrative courts.

Slovenia has concluded numerous double tax treaties based on the OECD Model Tax Convention to prevent double taxation and tax evasion. These agreements allocate taxing rights and include provisions on exchange of information and mutual assistance. Slovenian tax law aligns with EU directives such as the Anti-Tax Avoidance Directive (ATAD) to address base erosion and profit shifting (BEPS).

Transfer pricing rules require transactions between related parties to be conducted at arm’s length. Taxpayers must maintain comprehensive documentation demonstrating compliance. These provisions are aligned with OECD Transfer Pricing Guidelines and enforced rigorously by FURS to prevent profit shifting and ensure fair taxation.

Slovenian tax law offers targeted incentives for research and development, investment in green technologies, and startups. These include accelerated depreciation, tax credits, and exemptions designed to stimulate economic growth and innovation while ensuring adherence to EU state aid rules.

Slovenia continuously updates its tax legislation to incorporate EU directives and international standards, including digital taxation measures and enhanced transparency initiatives. These reforms aim to increase tax certainty, reduce avoidance, and harmonize the national system with the broader European tax environment.

Taxpayers may challenge FURS decisions through administrative appeals and judicial review. Alternative dispute resolution methods, including mediation and arbitration, are increasingly encouraged to reduce litigation costs and promote efficient conflict resolution.