• Service: Tax, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 10/8/2013

Slovenia - Corporate income tax rate; expanded thin capitalization rules 

October 9:  Measures affecting corporate income tax—repeal of a planned reduction in the rate of corporate income tax and expansion of the thin capitalization rules—were included in provisions published in the official gazette (no. 81) of the Republic of Slovenia on 4 October 2013.

Corporate income tax rate reduction is repealed

Under prior legislation, a reduction in the rate of corporate income tax in Slovenia was to be phased in until the rate was 15% in 2015 (the phase-in schedule was 17% in 2013, 16% in 2014 and 15% in 2015 and later).

The new measures set the corporate income tax rate at 17% for 2013 and later years. Thus, the planned reduction to 15% has been repealed.

Changes to thin capitalization rules

Slovenia’s thin capitalization rules apply to loans made to a taxpayer corporation by a shareholder who, at any time during the tax period, directly or indirectly owns at least 25% of the shares in the equity capital or voting rights of the taxpayer corporation, and if at any time during the tax period, these loans exceed the prescribed debt/equity ratio.

The recent changes extend the application of thin capitalization rules to “sister company” loans. Specifically, loans granted by a shareholder will be deemed also to be loans granted by a corporation deemed to be related to the taxpayer if the shareholder (or shareholder’s family members) directly or indirectly owns at least 25% of the shares in the equity capital or voting rights of the corporation and the taxpayer (i.e., sister companies).

The amount of the shareholder’s holding in the loan recipient’s equity capital is to be determined for the tax period as an average of all capital elements except net profit or loss for the period.

With these changes, retained losses that were historically not included in the calculation of equity capital now will be also considered.

Read an October 2013 report [PDF 53 KB] prepared by the KPMG member firm in Slovenia:
Changes of CIT Act effective as of 1 January 2014

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