In Slovenia, businesses have various corporate structures to choose from in accordance with the Companies Act. These include:

• a limited liability company;
• a public limited company;
• a partnership limited by shares;
• an unlimited company; and
• a limited partnership.

The primary distinction lies in the personal liability of shareholders. In limited liability and public limited companies, shareholders are not personally responsible for the company’s obligations. However, in other corporate forms, some or all members or shareholders may bear personal liability, risking their assets. The favoured choice for most businesses is typically the limited liability company.

Additionally, foreign companies can engage in business activities in Slovenia through branches.

Entities registered in Slovenia are subject to separate taxation as distinct legal entities.

Slovenian law does not recognise transparent corporate entities for tax purposes.

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

An exceptional 0% CIT rate is applicable to investment funds and management companies, established in accordance with the Act regulating investment funds and management companies, provided that at least 90% of the operating profit generated in the preceding tax period is distributed by 30 November of the tax period in question.

For alternative investment funds structured as non-corporate entities (comprising a set of assets) distinct from their alternative investment funds manager, they are not classified as taxpayers under the Corporate Income Tax Act (the “CIT Act”). Consequently, they are not subject to CIT. However, it is important to note that alternative investment funds organised as corporate entities do not receive favourable tax treatment.

Incorporated business and transparent entities are considered to be tax residents if they have a statutory seat or effective place of management located in Slovenia. Tax residents of Slovenia have to pay tax on profits achieved in Slovenia and in other countries according to the worldwide taxation principle.

Non-residents may also be subject to CIT in Slovenia if they have a permanent establishment (PE) in Slovenia. The definition of a PE of a non-resident, according to the CIT Act, is a place of business in Slovenia in or through which the non-resident carries out its activities in whole or in part. Slovenian tax legislation on PE is largely in line with the definition of PE in the Model Tax Convention. The only difference in the local definition of PE is that the place of business does not have to be fixed.

The standard corporate income tax rate is 19%. Notwithstanding this, the Act on Reconstruction, Development and Provision of Financial Resources was passed in 2023 in response to severe flooding and CIT is payable at a rate of 22% for periods between 2024 and 2028.

As the reduction in the tax base, together with unused tax credits from previous tax periods, is only recognised up to a maximum of 63%, the minimum effective tax rate is 7.03% (in the periods between 2024 and 2028 the minimum effective tax rate is 8.14%).

Slovenia follows the principles of accrual accounting for tax purposes. The tax base for CIT purposes is profit of the entity, determined as the surplus of revenues over expenses recognised in the income statement according to accounting standards, unless otherwise stipulated by the CIT Act. Taxable income includes revenues, which are determined according to accounting standards. This generally includes all income received and capital gains realised. Recognised expenses according to the CIT Act are those expenses required to acquire taxable revenue. Expenses that are not required to acquire revenue are expenses for which it follows that:

• they are not directly linked with performing activities and are not a consequence of performing activities;
• they are of a private nature; and
• they do not conform to normal business practice.

The most substantial adjustments for tax purposes are related to:

• the revaluation of assets, including the revaluation of financial investments, receivables and goodwill;
• capital gains, dividends and incomes similar to dividends;
• tax non-recognised expenditures;
• transfer pricing and thin capitalisation; and
• tax reliefs and provisions.

The R&D allowance enables a full 100% deduction for investments made in internal R&D activities and the acquisition of R&D services. Meanwhile, the investment allowance permits a 40% deduction for the amount invested in specific prescribed equipment and intangible assets, excluding real estate.

Additionally, an investment allowance targeting the digital and green transition allows a 40% deduction for investments in AI technology, big data, cloud computing, green technology, environmentally friendly innovations, cleaner, cheaper and healthier public and private transport, decarbonisation of the energy sector, energy efficiency of buildings and the introduction of other standards for climate neutrality.

The combined deduction is applicable up to a maximum of 63% of the actual tax base.

Notwithstanding the general rules on provisions ‒ according to which provisions are generally not fully recognised for tax purposes ‒ provisions made by banks, brokerage firms and insurance companies are considered to be a fully tax-deductible expense, up to a maximum amount to be determined by sectoral law.

As an exception to the general rule limiting the tax deductibility of revaluation expenses arising from the impairment of loans, revaluation expenses arising from the impairment of loans carried at amortised cost may be recognised as an expense by the bank up to a maximum amount determined by banking law.

Tax losses may generally be carried forward and offset up to a maximum of 50% of the company’s (Slovenian tax resident or foreign company’s PE tax base for a single tax period. However, tax losses may not be carried forward if (i) the company’s direct or indirect shareholder base has changed by more than 50%, and (ii) the company either did not carry out its business activities for two years before the change in ownership or changed its business activities two years before or after the change in ownership.

The carry back of losses is not allowed in Slovenia.

There are no general limits on interest deductibility, but transfer pricing and thin capitalisation rules apply (see 4.4 Transfer Pricing Issues).

Tax grouping is not allowed in Slovenia. Therefore, losses can only be utilised at an individual company level.

Capital gains are considered ordinary income and are taxed at the standard rate of taxation.

However, 50% of the capital gain (and losses) may be considered exempt if the taxpayer who made the gain participated in the capital by holding at least 8% of the shares or voting rights, and if the shares were held for more than six months and at least one person was employed on a full-time basis in the company in which the shares were sold. This treatment does not apply to the income derived from the sale of shares in companies, co-operative societies or other types of organisations that have their registered office or place of effective management in countries where the general or average nominal tax rate applicable to the profits earned by companies is lower than 12.5% and, if these countries are not EU member states, the country is included in a list published by the Ministry of Finance.

For the purpose of determining the Corporate Income Tax base, expenses related to the management and financing of investments in the capital of companies, co-operative societies or other types of organisations that facilitate tax exempt capital gains may not be taken into account up to an amount equal to 5% of the amount of capital gains that are exempt from the tax base.

Other taxes payable on a transaction include VAT, which is charged and paid on supplies of goods and services at a general rate of 22%, except for supplies of goods and services to which a reduced rate of 9.5% applies and supplies of goods and services to which a super reduced rate of 5% applies.

Real Estate Transfer Tax (2%) is payable on real estate transactions, Financial Services Tax (8.5%) is payable on certain financial services and Insurance Premium Tax (8.5%) is payable on insurance services.

Companies have to deduct payroll tax for their employees (advance payment of Personal Income Tax) and social security contributions.

Some business activities may also result in additional taxes for companies, such as environmental taxes and excise duties (alcohol, tobacco, energy sources).

Closely held local businesses in Slovenia are mostly incorporated as limited liability companies.

Business income is first subject to CIT (19%) and, if dividends are paid to the owner, an additional dividend tax (25%). Personal Income Tax rates are comparable to the final tax burden on business income, as Personal Income Tax rates are progressive, with tax brackets ranging from 16% in the lowest bracket to 50% in the highest bracket. However, it should be noted that at the individual level, income is also affected by social security contributions, which amount to 22.1% for employees and 16.1% for employers, so that in general employment income is more heavily burdened with duties.

In addition to the above, Slovenian legislation provides for the sui generis position of a sole entrepreneur who determines their tax base by applying flat-rate expenses. According to the aforementioned provisions, individuals generating business income and registered as sole entrepreneurs may opt to determine the tax base by taking into account flat-rate expenses. This means that 80% of their income up to EUR50,000 and 40% of the income over EUR50,000 is considered as expenses (up to a maximum of EUR80,000), and only the remaining 20% of the income constitutes the tax base, which is taxed at 20%. Thus, an effective tax rate of 4% applies to income up to EUR50,000, rising to 12% for income over EUR50,000 and up to EUR100,000, and a flat rate of 20% applies to income over EUR100,000. This regime applies to individuals whose business turnover does not exceed EUR300,000 in two consecutive years.

As this represents a uniquely low level of taxation, in practice many employments are covertly performed as sole entrepreneurships. If elements of a dependent relationship exist between an individual using a corporate form or acting as a sole entrepreneur and their contractor, all payments for services related to that relationship can be reclassified from business into employment income. Also, a lot of individual professionals are formed as sole entrepreneurs and are determining its tax base by taking into account flat-rate expenses. 

There are no other special tax rules that would prevent closely held companies from accumulating earnings for investment purposes.

Dividends and capital gains on the sale of shares are taxed at a flat rate of 25%.

The capital gains tax rate decreases the longer the shares are held. The tax rate falls to:

• 20% for a holding period of five to ten years;
• 15% for a holding period of ten to 15 years; and
• 0% for a holding period of more than 15 years.

There are no differences in the taxation of dividends or capital gains on the sale of shares if they come from a closely held corporation or a publicly traded corporation.

The following payments are subject to a 15% withholding tax if the recipient of the income is a legal entity:

• interest;
• dividends;
• royalties;
• income from the lease of real estate; and
• payment services of performing artists or sportspeople, payments for consulting, marketing, market research, staff recruitment, administration, information and legal services where payments are made to persons with a registered office or place of effective management in countries or jurisdictions that are included on the list published by the Ministry of Finance.

Pursuant to the local CIT Act, witholding tax (WHT) is not calculated, withheld and paid on dividends which are paid to a non-resident legal entity, who is resident in an EU or EEA member state other than Slovenia and subject to income tax in its country of residence, provided that the non-resident cannot claim the tax on dividends in its country of residence.

Where a Double Tax Treaty (DTT) exists between the relevant countries, the WHT rate on dividends, interest and royalties may be reduced in accordance with the provisions of the treaty.

The WHT rate on royalties and interest payments may also be reduced to zero under the Interest and Royalties Directive and the WHT rate on dividends may be reduced to zero under the Parent-Subsidiary Directive.

If the recipient of the income is an individual or if the income is paid under the dematerialised financial instruments, the general WHT rate is 25%.

Most of the foreign investors invest via EU member states, most commonly Luxembourg or Germany.

Other non-EU tax treaty countries from which investments to Slovenia are generally made include the USA, the UK and Switzerland.

There is currently no established practice by the Slovenian Tax Authorities regarding challenges to the use of treaty country entities by non-treaty country residents.

The main issues relate to loans between related parties; namely, the thin capitalisation rules and the prescribed interest rules.

Under the thin capitalisation rules, the interest on a loan is not deductible if the loan is received from a shareholder that owns, directly or indirectly, at least 25% of the equity capital or voting rights, or vice versa, and the total amount of the loan exceeds a debt-to-equity ratio equal to the shareholder’s share of the borrower’s equity in a given tax period. Currently, the applicable debt-to-equity ratio is set at 4:1. Any loan interest in excess of the debt-to-equity ratio is re-classified as a hidden profit distribution.

A major challenge is also the proof of scale in the provision of management services and other supporting services performed by related entities. The taxpayer must have clear evidence of the scope and nature of the services provided, and the necessity of the services also has to be proven.

Another important challenge is the restructuring of companies where there is a transfer of know-how, including the centralisation of certain internal business areas, such as the merging of intra-group shared services.

The use of related-party limited risk distribution arrangements with related entities is not challenged by the Tax Authorities solely on the basis of the nature of the arrangement. A distribution company in Slovenia must be remunerated in accordance with the arm’s length principle, in line with the company’s functional profile and the risks it bears, while companies with a limited risk distribution function may be remunerated at a lower level due to their function in the transaction.

The Tax Authorities’ interpretation of transfer pricing rules follows the OECD standards. In practice, the OECD Transfer Pricing Guidelines (the “OECD Guidelines”) are commonly used by the Tax Authorities and their Guidelines on transfer pricing can be relied upon by taxpayers as a reference to transfer pricing issues.

With regard to the mechanisms available to prevent transfer pricing disputes, a taxpayer may apply for a Unilateral or Multilateral Mutual Agreement Procedure (MAP). With regard to dispute resolution procedures, the taypayer may also apply to the Ministry of Finance for dispute resolution under a DTT in accordance with Article 25 of the OECD Model Tax Convention.

No figures are available from local authorities on the use of MAP procedures or the exact number of cases in Slovenia. According to the information available, only a few cases have been concluded, but several new cases are underway, also with the aim of concluding a MAP agreement.

Local legislation does not predict any compensating adjustments after the transfer pricing claim is settled. All adjustments for the purposes of CIT shall be performed based on arm’s length principle and at the level of the individual company.

Branches of non-local corporations are taxed in the same way as subsidiaries of non-local corporations.

Capital gains realised by a non-resident on the sale of shares in local corporations are not taxed in Slovenia. Taxation may apply if the investment in the shares of local corporations is performed by a permanent establishment of a non-resident.

A change of control may affect the benefits if the taxpayer has carried forward tax losses from previous periods (see 2.4 Basic Rules on Loss Relief). In addition, the change of control may affect the application of the benefits of certain DTTs, ie, the benefits of reduction of WHT under some DTTs are conditional on the recipient of the income also being the beneficial owner of the income and the change of control may affect the applicability of these DTTs or may result in a different DTT being applied.

Formulas are not used to determine the income of foreign-owned local affiliates. Standard transfer pricing methods in accordance with the OECD Guidelines are accepted for use in determining the income of a local affiliate, taking into account the arm’s length principle. Accepted methods include:

• the comparable uncontrolled price (CUP);
• the resale price;
• the cost-plus method;
• the transactional net margin method (TNMM); and
• the profit split method.

There are no set standards and rules regarding the deduction for payments by local affiliates for management and administrative expenses incurred.

There are no standard rules under which the amount of the management and administrative expenses would be considered as tax deductible. Also, there are no special rules in relation to determining the arm’s length price for management and administrative expenses. When determining the price for services by a non-local affiliate, the arm’s length principle must be taken into consideration, as management and other services are key points of focus for the Tax Authorities when conducting investigations in the field of transfer pricing.

Generally, the accepted method for management services is the cost-plus method, which determines the cost of services plus a mark-up. Administrative services are treated as ancillary services, which allow for no or minimum mark-up.

As stated in 4.4 Transfer Pricing Issues, according to the thin capitalisation rules, the interest on a loan is not deductible if a loan is received from a shareholder that owns, directly or indirectly, at least 25% of the equity capital or voting rights, or vice versa, where the total amount of the loan exceeds a debt-to-equity ratio of the shareholder’s share in the equity of the borrower in a certain tax period. Currently, the applicable debt-to-equity ratio is set at 4:1. Any interest on loans exceeding the debt-to-equity ratio is re-qualified as hidden profit distribution.

The rules on prescribed interest rates define a method for determining a reference interest rate on inter-company loans between related parties in a group in which a shareholder owns, directly or indirectly, at least 25% of equity capital or voting rights in the other party of the loan agreement or vice versa. The prescribed interest rate is the sum of a variable part of an interest rate (EURIBOR) with different mark-ups for credit ratings of the borrower and the maturity period of the loan. This is regarded as a safe-harbour interest rate and is commonly much lower than interest rates on the market. Thus, in the event that a foreign-owned local affiliate were to borrow from a non-local affiliate at a higher interest rate than the prescribed interest rate, it would be required to provide sufficient evidence that the higher interest rate corresponds to the arm’s length principle.

Local corporations, ie, Slovenian tax residents, are taxed on their worldwide income. Accordingly, foreign income earned by residents is subject to CIT in the same way as local income.

If the legal conditions are met, Slovenian tax residents can deduct foreign tax on foreign income included in their CIT base, ie, the inclusion of foreign income in the tax base of a resident in Slovenia is a condition for claiming a deduction for tax paid abroad in Slovenia. The foreign tax credit may not exceed the lesser of: (i) the amount of foreign tax on the foreign income that has been finally and actually paid; or (ii) the amount of tax that would have been payable under Slovenian CIT Act on the foreign income if the deduction had not been available.

If a DTT is concluded between Slovenia and the other country, the amount of the foreign tax calculated at the rate specified in the treaty shall thus be treated as the final foreign tax on the foreign income from that country. However, this rule applies whether or not the taxpayer has availed themself of the benefits of the enacted and applicable DTT.

Expenses related to foreign taxable income are deductible under the same rules that apply to the deductibility of expenses related to any other type of taxable income (domestic or foreign) and, therefore, there are no specific limitations.

Dividends from foreign subsidiaries located in the EU or a non-EU subsidiary established in a foreign jurisdiction not included in the blacklist from the Ministry of Finance are 100% tax-exempt; however, flat-rate expenses for the management of the financial investment in the amount of up to 5% of the income are not tax-deductible. In effect, 95% of the dividends are tax-exempt. If dividends are received from a subsidiary established in a foreign jurisdiction which is included in the blacklist, the dividends received from that subsidiary are fully taxable.

Any intangibles developed by local corporations can be used by or transferred to non-local subsidiaries in accordance with the transfer pricing rules and the arm’s length principle, and are treated as regular income of the local corporation.

Slovenia has implemented the Controlled Foreign Company (CFC) rules in line with the EU Anti-Tax Avoidance Directive (ATAD 1). The CFC income of a low-taxed CFC of a taxpayer is included in the taxpayer's tax base. Losses of a CFC are not included in the taxpayer's tax base, but may be carried forward to future tax periods. A CFC is generally defined as an entity whose profits are exempt or non-taxable in its member state of residence if:

• the taxpayer, individually or together with related companies, holds a direct or indirect “interest” of more than 50% in the entity; and
• the actual corporate income tax paid by the entity or permanent establishment is effectively less than half of the corporate income tax that would have been due in the taxpayer's member state of residence.

The taxpayer's tax base shall include the undistributed income of the controlled foreign company arising from the following income:

• interest or other income from financial assets;
• property rights or other income derived from intellectual property;
• dividends and income from the disposal of shares;
• income from financial leases;
• income from insurance, banking and other financial activities; and
• income from the issue of invoices to persons who derive income from sales and services on the basis of goods and services purchased from or sold to related persons and who have little or no value added.

As stated in 6.5 Taxation of Income of Non-local Subsidiaries under Controlled Foreign Corporation-Type Rules, there are rules regarding the substance of a foreign-related company to be considered a CFC. If a foreign-related company has a substance, performs economic activities and has available assets, human resources, equipment, offices, etc, and is not a case of artificial arrangements, the CFC-type rules will not apply.

Local corporations are taxed on gains on the sale of shares in non-local affiliates, in the same way as described in 2.7 Capital Gains Taxation.

Slovenia has implemented a general anti-abuse rule (GAAR), which allows for the authorities to disregard any potential arrangement or set of arrangements of which the main purpose is to obtain a benefit that is not in accordance with the purpose of the legislation. In particular, the GAAR provides that an arrangement or series of arrangements may be considered artificial if they are not entered for valid economic reasons.

Slovenia has also had local anti-tax avoidance rules in place since 2006, and specific case law has been developed in recent years.

The tax authority draws up an annual inspection plan, which is structured, in particular, according to:

• the size and status of the taxpayers;
• the type of tax; and
• the type of inspection in relation to the scope of the inspection.

Special emphasis has been placed on transfer pricing from a CIT perspective, and online sales from a VAT perspective. The objective criteria have been developed on the basis of a risk analysis. Part of the control is carried out by using the sampling method.

Slovenia has already implemented a number of the OECD’s Base Erosion and Profit Shifting (BEPS) measures in accordance with the Action Plan. Some of the recommendations have been implemented through the transposition of EU directives, while others have been directly implemented in the Slovenian tax legislation. The main changes that have already been implemented are the so-called CFC rules, hybrid mismatch rules and a general anti-avoidance rule. Below is a more comprehensive list of the implemented measures in Slovenia.

As for BEPS Action 2, Slovenia implemented the hybrid mismatch rules in 2019. They are fully in line with ATAD 1 and ATAD 2, which follow the BEPS principle with regard to hybrid mismatches. The rules are transposed into the Slovenian CIT Act. Slovenia has also implemented a GAAR in line with ATAD 1, meaning that the substance-over-form and economic substance principles can be applied in both domestic and cross-border cases.

In 2021, Slovenia implemented the so-called CFC rules (BEPS Action 3), thus strengthening the rules to curb profit shifting to low-tax jurisdictions. ATAD 1 (Council Directive (EU) 2016/1164) was transposed into the Slovenian CIT Act accordingly and does not provide for any deviations or local specifics.

Limitation on interest deduction exists in Slovenia. The CIT rules stipulate the limitations for deductibility of interest on loans, including the so-called thin capitalisation rule in accordance with which any interest on loans exceeding the 4:1 debt-to-equity ratio is generally recharacterised to a hidden profit distribution. The implementation of the EBITDA limitation rule (BEPS 4) is currently in the legislative process.

With respect to BEPS Action 12, Slovenia implemented Council Directive 2018/822 (DAC 6), which introduced aggressive tax-planning reporting obligations on EU member states and third parties. DAC6 has been implemented into the Slovene legislation with the amendment to the Tax Procedure Act, which came into effect on 1 July 2019. The amendment is in line with DAC6, with the only local specifics being the provisions regarding professional secrecy and penalties for lack of reporting.

In terms of BEPS Action 13, Slovenia adopted the country-by-country (CbC) reporting requirement. In 2016, Slovenia was among the first 31 countries to sign tax co-operation agreement, enabling the automatic sharing of CbC information (the Multilateral Competent Authority Agreement on the Exchange of CbC Reports, CbC MCAA). In Slovenia, the CbC requirement applies to multinational enterprise groups with consolidated group revenue exceeding EUR750 million, thus fully aligning with the Action 13 minimum standard. Slovenia also follows the three-tiered standardised approach for transfer pricing documentation, including Master File, Local File, and CbC reports. A Slovenian entity that is part of a multinational enterprise group is also liable to file a CbC notification, which is a part of the CIT return. 

Slovenia has also implemented the Action 14 (Dispute resolution mechanisms) minimum standard to strengthen the MAP for resolving tax treaty disputes. As such, Slovenia participates in improved mechanisms for resolving international tax disputes through the MAP.

Slovenia has also ratified the Multilateral Instrument to Modify Bilateral Tax Treaties (MLI) (BEPS Action 15) in 2017, which came into force as of 1 July 2018. Slovenia has otherwise concluded more than 60 individual tax treaties.

For the so-called BEPS 2.0 – Pillar II ‒ Slovenia adopted the global minimum corporate tax rate of 15% under Pillar Two, effective for large multinational enterprises (MNE) for business years beginning on or after 31 December 2023.

The government mostly follows the approach, practice and recommendations of other EU countries on BEPS and is therefore not a leader of changes in the field of BEPS. Nevertheless, the BEPS recommendations are always taken into account and thoroughly followed, so the BEPS action plans certainly have the support of the government in Slovenia.

Slovenia is currently in the process of implementing Pillar Two, but there is no publicly available information on Pillar One.

International tax does not have an especially high public profile in Slovenia and tax policies mostly follow the approach of the EU.

As Slovenia does not have a highly competitive tax policy objective, there is strong support for the BEPS Action Plan and other OECD or EU recommendations.

Slovenia has a fairly average CIT rate of 19% and allows a considerable amount of deductions and incentives for R&D and employment, but nothing out of the ordinary that might be vulnerable or affected by the BEPS Action Plan.

Slovenia has already implemented provisions on the hybrid mismatch, which came into effect in 2020. Hybrid mismatches result in double deduction, deduction of income in a country where the income is not included in the taxable base of another or non-taxation of the income in a country that is not included in the taxable base of another.

Additionally, in 2022, new provisions were implemented in Slovenia on reverse hybrid mismatches, which stipulate that if one or more non-resident entities which together, directly or indirectly, participate in at least 50% of shares in a hybrid entity in Slovenia and the hybrid entity is located in a jurisdiction that treats the hybrid entity as a taxable person, the hybrid entity will be treated as a resident of Slovenia and will also be taxed accordingly.

Slovenia taxes its residents on a worldwide income principle, while it also imposes a withholding on the majority of the incomes with a source in Slovenia. As Slovenia already has thin capitalisation rules in place, any proposals on interest deductibility limitations would not result in much difference from the current situation.

The CFC rules are already in place in Slovenia and as local tax system is not based on a territorial tax regime the CFC rules are not defective in any significant respect.

Rules on the prevention of tax treaty abuse as provided by BEPS Action 6 have not yet been implemented, but a general anti-abuse rule (GAAR) is already in place in Slovenia (see 7.1 Overarching Anti-avoidance Provisions).

As with other transfer pricing matters, Slovenia primarily follows the recommendations and practices of the OECD Guidelines, therefore no radical changes in the field of transfer pricing have resulted from the BEPS Action Plan.

Slovenia was among the first 31 countries to sign a tax co-operation agreement enabling the automatic sharing of CbC information, and, in 2016, Slovenia implemented rules for automatic information exchange for large MNEs with a consolidated group turnover of at least EUR750 million, in accordance with the BEPS Action 13. The instructions, adopted with the amendments to the Implementation of the Tax Procedure Act, are in line with the instructions of Council Directive (EU) 2016/881.

A new law to levy a digital services tax on multinational tech companies was proposed in parliament in 2020 but was struck down, as the government supports a co-ordinated approach with the EU, as is its practice with other issues related to international taxation in Slovenia.

The government is aware that a response to the digitalisation of the economy and business models is required in the area of taxation, but no action is expected from Slovenia on its own without any prior guidance from the EU on this topic.

As yet, no provisions are in place in Slovenia with special regard to the taxation of offshore intellectual property. As this is quite a specific topic, Slovenia will most likely wait for guidance from and action by the EU and other EU member states.