Slovenia

Corporate - Withholding taxes

Last reviewed - 10 January 2020

In Slovenia, tax must be calculated and withheld on the payments made by residents and non-residents on Slovenian-sourced income to recipients outside Slovenia.

Payments to which the WHT rules apply include payments for dividends, interest, copyrights, patents, licences, leases on real estate situated in Slovenia, services of performing artists, and services charged from low-tax jurisdictions.

The WHT rate is 15%.

If a DTT exists, the WHT rate may be reduced in line with the provisions of the treaty. Similarly for payments of interest, royalties, and dividends within Europe, the Interest and Royalties Directive and the Parent Subsidiary Directive, respectively, may also reduce this WHT rate to zero.

Furthermore, WHT is not deducted on dividends paid to a parent company in another EU member state if those dividends are subject to an exemption from tax in the hands of the recipient, provided certain conditions are met.

Subject to certain conditions, tax is not required to be withheld on interest on non-exchangeable debt securities issued outside Slovenia by a Slovenian tax resident corporation through a public placement on an international clearing system (i.e. Euroclear).

WHT is applicable only for explicitly determined types of services (i.e. consulting, marketing, staffing, administration, information, and legal services), provided they were made to countries with an average CIT rate not exceeding 12.5%, where such a country was also stated on a separate list published by the Ministry of Finance.

Treaties in force

Recipient WHT (%)
Dividends (1) Interest (2) Royalties
Non-treaty 15 15 15
Treaty:      
Albania 5/10 7 7
Armenia 5/10 10 5
Austria 5/15 5 5
Azerbaijan 8 8 5/10 (8)
Belarus 5 5 5
Belgium 5/15 10 5
Bosnia and Herzegovina 5/10 7 5
Bulgaria 5/10 5 5/10 (5)
Canada 5/15 10 10
China, People’s Republic of 5 10 10
Croatia 5 5 5
Cyprus 5 5 5
Czech Republic 5/15 5 10
Denmark 5/15 5 5
Estonia 5/15 10 10
Finland 5/15 5 5
France 0/15 5 5
Georgia 5 5 5
Germany 5/15 5 5
Greece 10 10 10
Hungary 5/15 5 5
Iceland 5/15 5 5
India 5/15 10 10
Iran 7 5 5
Ireland 5/15 5 5
Israel 5/10/15 (4) 5 5
Italy 5/15 10 5
Japan 5 5 5
Kazakhstan 5/15 10 10
Korea 5/15 5 5
Kosovo 5/10 5 5
Kuwait 5 5 10
Latvia 5/15 10 10
Lithuania 5/15 10 10
Luxembourg 5/15 5 5
Macedonia 5/15 10 10
Malta 5/15 5 5
Moldova 5/10 5 5
Netherlands 5/15 5 5
Norway 0/15 5 5
Poland 5/15 10 10
Portugal 5/15 10 5
Qatar 5 5 5
Romania 5 5 5
Russian Federation 10 10 10
Serbia/Montenegro 5/10 10 5/10 (6)
Singapore 5 5 5
Slovakia 5/15 10 10
Spain 5/15 5 5
Sweden 5/15 0 0
Switzerland 0/15 5 5
Thailand 10 10/15 (9) 10/15 (7)
Turkey 10 10 10
Ukraine 5/15 5 5/10 (6)
United Arab Emirates 5 5 5
United Kingdom and Northern Ireland 0/15 5 5
United States 5/15 5 5
Uzbekistan 8 8 10

Treaties not yet in force (3)

Recipient WHT (%)
Dividends (1) Interest (2) Royalties
Egypt 8/13 13 15
Morocco 7/10 10 10

Notes

  1. Under certain treaties, the WHT rate depends on whether, and to what extent, the recipient participates in the capital of the distributor. Generally, if the recipient holds a participation of more than 25% in the distributing company, the dividends are subject to a lower 5% WHT rate. The higher WHT rate is, however, normally due when the participation is less than 25%.
  2. Some DTTs include specific provisions whereby interest payments are subject to a 0% WHT rate if certain conditions are met.
  3. Ratified international treaties that are not yet in force and are not used in Slovenia.
  4. 5% rate if the beneficial owner is a company (other than a partnership) that directly holds at least 10% of the capital of the company paying the dividend; 10% rate if the beneficial owner is a company that directly holds at least 10% of the capital of the company paying the dividends and the dividends are paid out of profits which by virtue of the law of the state in which the payer is a resident are exempt from company tax or subject to company tax at a rate that is lower than the normal rate in that state; 15% rate applicable in all other cases.
  5. 5% rate applicable to the gross amount of: (i) royalties paid for the use of, or the right to use, any copyright of literary, artistic, or scientific work (but not including cinematograph films) and (ii) royalties paid for the use of, or the right to use, industrial, commercial, or scientific equipment, 10% rate applicable in all other cases.
  6. 5% rate applicable to royalties for the use of, or the right to use, any copyright of literary, artistic, or scientific work, including cinematograph films or films or tapes used for radio or television broadcasting; 10% rate applicable to royalties for the use of, or the right to use, any patent, trade mark, design or model, plan, secret formula or process, or for the use of, or the right to use, industrial, commercial, or scientific equipment, or for information concerning industrial, commercial, or scientific experience.
  7. 10% rate applicable to royalties for the use of, or the right to use, any copyright of literary or artistic work including motion pictures, live broadcasting, film, tape, or other means of the use or reproduction in connection with radio and television broadcasting, and for the use of, or the right to use industrial, commercial, or scientific equipment; 15% rate applicable to royalties in all other cases.
  8. 5% rate applicable to copyright, as defined by the Copyright and Related Rights Act; 10% rate applicable to other property rights.
  9. 10% rate applicable to the gross amount of interest if received by a financial institution (including an insurance company); 15% rate applicable to the gross amount of interest in all other situations.