Slovenia

Slovenian tax residents are liable to pay corporate income tax (CIT) on their worldwide income. Slovenian tax non-residents are taxed only on income from sources in Slovenia, including income earned through permanent establishments (PEs) in Slovenia.

Due to the floods causing highly material damage to Slovenian infrastructure in August 2023, the Slovene government passed a Law on reconstruction, development, and the provision of financial resources to finance the reconstruction of the infrastructure. One of the provisions of the Law is also an increase in the CIT rate to 22% (from 19%) for years 2024 to 2028. Thus, the prepayments made in FY24 shall be calculated based on the newly adopted CIT rate of 22%.

Non-profit taxpayers and charitable organisations, associations, foundations, etc. are exempt from CIT on their non-profit-making activities.

Investment funds, as well as pension funds and pension insurance companies, may be taxed at a rate of 0% if certain conditions are met.

Pillar Two

At the end of 2023, the Minimum Tax Act ("ZMD") came into force, which determines and defines the payment of minimum tax in Slovenia. In 2022, the EU Council adopted Council Directive (EU) 2022/2523 on ensuring a global minimum level of taxation for multinational enterprise groups and large-scale domestic groups in the Union (the so-called Pillar II directive), which Slovenia transposed into local legislation through the Minimum Tax Act.

The Purpose of the ZMD is to ensure minimum taxation of income of large international and domestic groups with an effective minimum tax rate of 15%.

The minimum tax consists of top-up tax and qualified domestic top-up tax, which are paid on excess income of all entities in a particular jurisdiction with an effective tax rate below 15%.

The top-up tax is calculated based on the Income Inclusion Rule ("IIR") or based on the Undertaxed Payment Rule ("UTPR"). The latter acts as a backstop rule and imposes payment of top-up tax that was not paid under the IIR. In addition, part of the minimum tax is also the qualified domestic top-up tax ("QDMTT") which ensures Slovenia's right to taxation under minimum tax rules for all constituent entities located in Slovenia that are part of a group reaching the aforementioned consolidated revenue threshold. 

The ZMD also provides for calculation simplifications and exemption from top-up tax and domestic top-up tax, which shows that there are three groups of obligations that taxpayers must consider in the minimum taxation systems.

It is important to highlight that all constituent entities, regardless of whether the entity will be obligated to pay (domestic) top-up tax, must submit GloBE Information Return as well as the calculation itself or (domestic) top-up tax. In case of multiple relevant companies in Slovenia, it is possible to appoint a designated filing entity in both cases. 

Tonnage tax

A company may request to be subject to tonnage tax instead of CIT if it meets certain conditions (i.e. it operates in maritime transport in international shipping) and notifies the tax authorities in advance.

The tax base for tonnage tax is the sum of the tax bases for each of an entity’s ships that are included in the tonnage tax regime. The tax base for a particular ship is calculated by multiplying the number of ship operating days by the daily tax base shown in the following table:

Local income taxes

There are no municipal or local taxes on income in Slovenia.