Page 50 - Mazars Central and Eastern European tax guide 2023

Slovenia VAT options in of whether they are delivered on physical media or electronic
forms. VAT-exempt services include services of public
Slovenia Applicable / limits interest, as well as banking services, insurance, investment-
related services, gambling, certain services provided
EUR 10,000/year by medical doctors and dentists, etc. EC Sales lists (IC report)
Distance selling From 1 July 2021 the OSS system
Mazars Consulting d.o.o. is applicable. are obligatory in Slovenia and should be submitted by the
20th day of the month following the taxable period. For
Verovškova ulica 55A Call-off stock ü cross-border sales to consumers, a threshold of EUR 10,000
1000 Ljubljana, is applied in Slovenia. Electronically supplied services
Slovenia VAT group registration No to consumers worth less than EUR 10,000 are subject
Phone: +386 59 049 500 to Slovenian VAT rules. From 2019, Slovenia incorporated
EUR 400,000/year.
www.mazars.si Cash transactions between companies the requirements of the EU Vouchers Directive (Directive
are regulated by the Tax Procedure
Act, which sets out both limitations 2016/1065) into domestic law.
and exceptions. The Tax Procedure Other indirect tax types in Slovenia include excise duty,
Act stipulates that legal persons,
sole proprietors, individuals engaged insurance tax, tax on financial services, motor vehicle tax,
in self-employment, administrative customs, etc.
Corporate taxes and other direct taxes profit modified by various increasing and decreasing items. Cash accounting – yearly and other state bodies, self-governing
A company may request to be subject to tonnage tax instead amount in EUR (approx.) local authorities and holders of public Personal income tax / Social security system
powers must transfer payments for
A special rate of 0% applies to investment funds, pension of corporate tax if it meets certain conditions (i.e., it operates goods and services to transaction
funds and insurance undertakings for pension plans, under in international maritime shipping) and notifies the tax accounts. Similarly, a legal person shall Personal income tax rates are progressive from 16% to 50%
certain conditions. The tax base is the pre-tax (accounting) not be obliged to transfer payments for (change from 2023 onwards), and apply on active income
authorities in advance. The tax base for tonnage tax is the goods and services supplied by it to the sources (employment, business income, agriculture and
transaction account of a legal or natural
sum of the tax bases for each of an entity’s ships that are person carrying out an activity, provided forestry, other income). Capital and rental income is taxed
Transfer pricing in Slovenia included in the tonnage tax regime. In 2023 changes were that the individual payment does not at a flat rate (dividends at 25%, interest at 25%, capital
exceed EUR 420.
Since 2005 in Article introduced affecting the determination of the tax base using gains from 0% to 25%, depending on the holding period,
Arm’s length principle ü 16 of the Slovene Corporate standardised expenditure for taxable persons with income Yes, special treatment for tax non- rental income at 25% (10% lump sum costs or actual costs
residents with use of Slovene VAT
Income Tax Act (CITA) between EUR 50,000 and EUR 100,000, if employing one full Import VAT deferment ID number, simplification can be used deductible).
Slovene Ministry of Finance time employee for at least 9 months for a continuous period only in cases where they appoint tax
Documentation liability ü issued regulations (previously five months) special tax treatment for 2023 can representative. Social security contributions are applicable on income
on TP on 1 January 2007 be used. In the other cases, with income up to EUR 50,000, Construction works and supply of staff from employment and are 16.10% for the employer and
APA ü Available there are no changes in the notification. Losses can be carried Local reverse charge in relation to construction works, supply 22.10% for the employee. Self-employed individuals
of immovable property (limited), supply
of waste and used material based
Country-by-Country Since 2016 forward without limitation and can only be used for up to 50% on specifications, transfer of greenhouse (business income) pay their own social security
liability ü of the tax base. In addition, special rules apply in cases gas emission allowances. contributions depending on the circumstances of the case.
Master file-local file of M&A transactions. Slovenia uses thin capitalisation rules The examples below show the cost of the employer and
(OECD BEPS 13) ü Since 2006 (4:1), but they do not apply if the shareholders are financial Option for taxation the employee in case of the minimum wage level and the
applicable institutions and if the taxpayer provides evidence that letting of real estate ü average wage in the private sector. There are a number
Penalty they could have received the loan surplus from a lender of personal allowances that apply individually depending
If adequate transfer that is a non-associated enterprise. There is a range of tax supply of used real estate ü on the personal status of the individual.
pricing documentation allowances for new investments and R&D, new employments VAT registration
is not in place, the penalty and the employment of disabled persons, donations and threshold EUR 50,000/year
is EUR 1,200 to EUR voluntary supplementary pension insurance. From January
15,000 for micro and small
lack of documentation ü legal entities, EUR 3,200 2022, there is a new tax allowance for investment in the
to 30,000 for medium and digital and green transition. Provisions governing the general
large legal entities and anti-avoidance rule and CFC as a part of the EU ATAD I are Average wage
up to EUR 4,000 for the applicable from 2019. Wage related taxes in Slovenia Minimum wage
responsible representative. A withholding tax of 15% is applied on dividends, interest, in private sector
30% of underpaid tax royalties and rental income paid by a Slovenian company in EUR in EUR
for micro and small legal to a foreign company. However, if conditions are met, 1,203
entities (underpaid tax from an exemption (or decrease in the percentage of withholding 2,032
EUR 1,500 to tax) is applicable to payments to EU residents (under Total wage cost 1,397 116.13% 2,359 116.09%
EUR 150,000). the parent subsidiary directive & the interest and royalty Employer's contribution** 194 16.10% 327 16.10%
• 45% of underpaid tax
tax shortage ü for medium and large directive), and under international double taxation treaties Gross salary 1,203 100.00% 2,032 100.00%
(there are currently over 50 treaties).
companies (underpaid Real estate transfer tax (RETT) is applied on the transfer Employees' contributions** 266 22.10% 449 22.10%
tax from EUR 2,000 of immovable property at the rate of 2% the if transaction Tax and surtax* 83 6.90% 230 11.32%
to EUR 300,000). • is not subject to VAT where the tax base is selling price. Net salary 854 70.99%
Responsible representative DAC7 obligatory reporting from 2023. 1,353 66.58%
up to EUR 5,000. * Tax base differs from the gross salary, deductions apply.
** In the case of a minimum wage, a higher calculation base must be used to calculate social security contributions.
Related parties ü VAT and other indirect taxes Teja Paulin
For interest rates in line with The general tax rate is 22%; a reduced rate of 9.5% Tax Partner
Safe harbours ü the government regulations applies to some goods, e.g., food, water supply, carriage Phone: +386 59 049 500
for thin cap, a 1:4 ratio.
Level of attention paid by Tax of passengers and their personal luggage, and a reduced Mobile: +386 40 534 522
Authority 8/10 rate of 5% applies to books and newspapers, regardless E-mail: teja.paulin@mazars.si

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