• Service: Tax, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 6/17/2013

Slovenia - Proposals to amend tax rate, thin capitalization rules 

June 17: There are proposals in Slovenia to amend a scheduled phase-down reduction in the rate of corporate income tax, and to amend the thin capitalization rules.

Corporate income tax rate reduction

The corporate income tax rate was 18% for the 2012 tax year.

The corporate income tax rate currently is to be reduced according to this schedule:

  • 17% for 2013
  • 16% for 2014
  • 15% for 2015 and later tax years

There is now a legislative proposal to set the corporate income tax rate at 17% for 2013 and later years, thus stopping the scheduled phase-down of the rate after 2013.

Proposed change to thin capitalization rules

Another proposed change would amend the thin capitalization rules in Slovenia.

Currently, the thin capitalization rules apply to loans granted 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 company, provided that at any time during the tax period the shareholder loans exceed the prescribed debt / equity ratio.

The proposed change would extend application of the thin capitalization rules to loans granted by a related company (i.e., with respect to loans granted by a shareholder or family members who directly or indirectly own at least 25% of the shares in the equity capital or voting rights of the lending company and the taxpayer).

The proposal includes measures for determining a shareholder’s holding in the loan recipient’s equity capital for a tax period.

Read a June 2013 report [PDF 160 KB] prepared by the KPMG member firm in Slovenia: Proposal to amend the CIT Act in Slovenia

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