Slovenia

Definition of a ‘plant’ revised for tax-neutral reorganisations

On 23 October 2025, the National Assembly of the Republic of Slovenia adopted the Act on Amendments to the Corporate Income Tax Act (hereinafter referred to as 'ZDDPO-2V'). The amended provisions apply to tax periods beginning on or after 1 January 2026.

The amendment revises the definition of a ‘plant’ relevant for tax-neutral transfers of assets and divisions. Under the amended wording, a plant consists of the assets and liabilities attributable to a part of the company that, at the time of the transfer, spin-off, merger, or division, represents an independent business activity from an organisational perspective. The key change is the clearer emphasis on the timing of the assessment, as it is no longer sufficient to argue that the transferred assets may become capable of operating independently only at some future point. Instead, the transferred assets and liabilities must already form an organised and functionally independent activity when the transaction is carried out.

Tax treatment of certain investment funds revised

ZDDPO-2V, adopted on 23 October 2025 and effective from 1 January 2026, also revised the 0% corporate income tax regime for certain investment funds. Under the new rules, eligible funds must distribute at least 75% of the previous tax period’s business profit, excluding unrealised gains, by 30 November of the current period. In addition, income from renting, finance leasing, and lending is excluded from the 0% regime and must be reported separately. The regime was also extended to certain ELTIF, EuSEF, and EuVECA funds.

Changes to the procedure for claiming tax neutrality in corporate reorganisations

On 19 November 2025, Slovenia adopted amendments to the Tax Procedure Act (hereinafter referred to as 'ZDavP-2P'), effective from 1 January 2026, which significantly changed the procedure for claiming tax-neutral treatment in corporate reorganisations, including transfers of assets, share-for-share exchanges, mergers, and divisions. Under the new rules, the notification is no longer structured as a pre-transaction step that may lead to an advance refusal decision before the transaction takes effect. Instead, the relevant notification must generally be filed after the transaction has been carried out or registered, as applicable, but before the filing of the tax return in which the effects of the claimed tax treatment are reflected. As a result, taxpayers may still claim tax-neutral treatment, but compliance with the statutory conditions will in practice be assessed ex post, generally in the course of a tax audit of the relevant tax return. The amendments also introduce more detailed notification, documentation, and record-keeping requirements, as well as obligations to notify the other parties involved in the transaction.

CIT payment deadline change

ZDavP-2P, adopted on 19 November 2025 and effective from 1 January 2026, also changed the reference point for CIT payment deadlines. Previously, taxpayers had 30 days from the actual submission date of their tax return to pay any tax due. Under the new rules, the payment deadline is calculated from the statutory deadline for submission of the tax return, rather than from the actual date of submission.