Corporate taxation:
Residence – An entity is resident if it has its business seat or place of effective management in Slovenia.
Basis – Residents are taxed on worldwide income; nonresidents are taxed only on Slovenia-source income. Foreign-source income derived by residents is subject to corporate income tax in the same way as Slovenia-source income.
Taxable income – Corporate income tax is imposed on income derived by residents and by nonresidents operating through a permanent establishment in Slovenia.
Expenses related to the business activities of the entity generally may be deducted if they are properly documented.
Taxation of dividends – Dividends are exempt if received from another Slovene taxpayer, an EU subsidiary or a non-EU subsidiary established in a country not included on the “black list” published by the Ministry of Finance.
Capital gains – Capital gains are treated as ordinary income, although gains arising from a transaction subject to the EU merger directive are exempt. An exemption of 50% of gains derived from the sale of shares is available if, inter alia, the shares represent a participation of at least 8% and the shareholding has been held for more than 6 months and at least 1 person is employed on a full-time basis in this period. Fifty percent of a capital loss is not recognized (unless the loss arises from a venture capital investment).
Losses – Tax losses generally may be carried forward indefinitely. The carryback of losses is not permitted.
Rate – The standard rate is 18% for calendar year 2012 (reduced from 20% on 27 April 2012). The rate will further reduce to 17% for 2013, 16% for 2014 and 15% for calendar year 2015 and onwards. A special rate of 10% applies to operations in special economic zones and a 0% rate applies to certain funds and pension insurance undertakings and venture capital companies.
Surtax – No
Alternative minimum tax – No
Foreign tax credit – A tax credit is available for foreign tax paid. The credit is equal to the lesser of the amount of foreign income tax actually paid or the amount of Slovene tax payable on the foreign income.
Participation exemption – All dividends are exempt from tax.
Holding company regime – No, but there are some exemptions under the “Capital gains” special regime.
Incentives – These include a deduction of 100% (increased from 40%) of the amount invested in internal R&D activities and the purchase of R&D services; a 40% (increased from 30%) deduction of the actual amount invested in equipment and intangible assets up to the amount of the tax base (previously limited to EUR 30,000); relief for donations is limited to 0.3% of taxable income and an additional 0.2% for special purposes; relief for voluntary supplementary pension insurance is limited to 24% of obligatory contributions for pension and disability insurance; relief for employment of disabled persons is 50% of salary of such persons (70% of the salary for physically disabled and deaf individuals); and relief for employment of unemployed persons younger than 26 years or older than 55 who were registered as unemployed at the Employment Office of Slovenia for at least 6 months (45% of the salary for the first 24 months of employment).
Withholding tax:
Dividends – Dividends paid to a nonresident are subject to a 15% withholding tax unless the rate is reduced under a tax treaty or exempt under the EU parent-subsidiary directive.
Interest – Interest paid to a nonresident is subject to a 15% withholding tax unless the rate is reduced under a tax treaty or exempt under the EU interest and royalties directive.
Royalties – Royalties paid to a nonresident are subject to a 15% withholding tax unless the rate is reduced under a tax treaty or exempt under the EU interest and royalties directive.
Technical service fees – Service fee payments are subject to a 15% withholding tax if made to persons with a head office outside the EU and the country is on the list published by the Ministry of Finance.
Branch remittance tax – No
Other – No