Slovenia taxes residents on worldwide income and non-residents on Slovenia-source income only. Slovenia operates a self-assessment system for corporate tax, with the Financial Administration (FURS) conducting post-filing review.
The Slovenian tax year is the calendar year. The individual filing deadline is generally the end of April/early May of the following year for the pre-filled return process; corporate filing deadline is generally 3 months after the fiscal year-end.
Slovenia's headline corporate income tax (CIT) rate is 22%.
The headline personal income tax (PIT) rate is 50%.
The standard VAT/GST (or equivalent consumption tax) rate is 22%.
An individual is a Slovenian tax resident if they have a formal residential tie (permanent residence in Slovenia, Slovenian public employee posted abroad, or former Slovenian resident now employed at an EU institution) or an actual residential tie (habitual abode, center of personal and economic interests, or presence exceeding 183 days in a taxable year in Slovenia). Presence under six months generally means non-resident status unless significant residential ties are established before the six-month mark. Residents are taxed on worldwide income; non-residents only on Slovenia-source income.
A non-Slovenian entity has a Slovenia permanent establishment through a fixed place of business or a dependent agent habitually concluding contracts in Slovenia on the entity's behalf, following the OECD Model Treaty definition as applied under Slovenian domestic law and any applicable tax treaty.
Slovenia's CFC regime (effective January 1, 2019) applies where a Slovenian taxpayer, alone or with related parties, holds direct or indirect participation of more than 50% of voting rights, capital, or profit entitlement in a foreign entity not subject to tax under Slovenia's Corporate Tax Act. Attributed income is included proportionally, with foreign losses excluded from the Slovenian taxable base and actually-paid foreign tax creditable to avoid double taxation. Slovenia is among the European countries whose CFC rules tax only the CFC's passive income rather than its full income.
Slovenia abolished its thin capitalization rule (the 4:1 debt-to-equity ratio under Article 32 of the Corporate Income Tax Act) effective January 1, 2025, per PwC and multiple 2025-dated legal alerts (Lexology, Karanovic & Partners, EY). This did not leave a gap: an ATAD-based EBITDA interest limitation rule had already been introduced separately from January 1, 2024 and continues to apply as Slovenia's sole interest-limitation mechanism going forward - interest expense is deductible up to the higher of 30% of tax-EBITDA or a EUR 3 million absolute threshold (increased from a lower amount as part of the same 2025 reform), applying to companies with a direct or indirect majority shareholder of at least 25%, not only related-party debt specifically.
Slovenia does not use an elective check-the-box classification system; entity classification generally follows the entity's actual legal characteristics. Slovenia has implemented ATAD2-aligned anti-hybrid rules denying deductions for payments producing a hybrid mismatch outcome.
No foreign bank account or foreign financial asset reporting regime exists requiring residents to separately disclose foreign accounts; foreign income is reported through the standard annual tax return.
Slovenia provides a 95% participation exemption for qualifying dividends and capital gains from a subsidiary meeting minimum ownership and holding-period conditions.
Slovenia has a real foreign tax credit regime available to both individuals and companies for foreign tax paid on foreign-source income also taxed in Slovenia, capped at the Slovenian tax otherwise due on that income.
Slovenia maintains double tax treaties with more than 60 countries.