Slovenia

Taxable period

The tax period should be the calendar year. However, a tax period may differ from the calendar year but may not exceed a period of 12 months. In this case, the tax authorities must be informed about the chosen tax period, and the taxable entity will not be allowed to change its tax period for the following three years.

Tax returns

A tax return must be submitted to the tax authorities by the end of the third month following the end of the tax year.

Payment of tax

CIT is paid in advance in monthly instalments (if the amount of prepayment exceeds EUR 400 per month) or in quarterly instalments (if the amount of prepayment is less than EUR 400 per month) determined on the basis of the previous year’s assessment.

The final CIT payment must be made within 30 days of the tax return submission.

Tax audit process

Slovene legislation does not define an audit cycle. However, we understand that the Slovene tax administration has its own criteria for how to determine audit targets, which is in accordance with their annual tax plan.

Statute of limitations

Under Slovene legislation, a tax inspection may be initiated within five years from the date when a tax return was due for submission to the tax authorities. However, the five-year period runs following each interrupting act (generally, certain actions by the Tax Office or the taxpayer within the tax period may be considered as interrupting acts), but may not surpass a maximum of ten years counting from the date when the tax return is due. A concluded tax inspection will foreclose any further tax authorities’ inspection only for the period and the items that were subject of the concluded tax inspection. Any issue not examined remains open for a future tax inspection. The right of the tax authorities to assess and collect tax permanently expires after ten years counted from the date when the tax return is due.

Topics of focus for tax authorities

In recent years, Slovene tax authorities have been focusing on appropriateness of transfer pricing for multinational companies, ranging from the general transfer pricing documentation compliance to appropriate set up in terms of management service fees, loan agreements, etc. One of the hot topics is also potential PE in Slovenia.

Fiscal verification of invoices

According to the Act on Fiscal Verification of Invoices, all legal and natural persons that perform cash transactions and are obligated to keep books and records must use certified tax registers. No exceptions are envisaged, so electronic confirmation of invoices applies to anyone that is obligated to use receipts in accordance with the VAT Act. Certified cash registers are connected to the central information system of the financial authority via the Internet, so processed invoices are verified and saved in real time.