Slovenia Corporate Income Tax

Corporate income tax rates and base (2025)

Slovenian-resident companies pay corporate income tax on worldwide profits at a flat rate. The standard rate was temporarily raised to 22% for tax years 2024-2028.

• Standard CIT rate (2024-2028) — 22% percent (Corporate Income Tax Act (ZDDPO-2))
• Pre-2024 standard rate — 19% percent (Corporate Income Tax Act (ZDDPO-2))
• Reduced rate — qualifying investment funds, pension funds, insurers — 0% for certain qualifying funds/vehicles meeting statutory conditions percent ((approx — verify which vehicles qualify)) (Corporate Income Tax Act (ZDDPO-2))
• Tax base — Accounting profit per Slovenian/IFRS standards, adjusted for tax (non-deductible expenses, exempt income, tax depreciation) (Corporate Income Tax Act (ZDDPO-2))
• Minimum effective tax base limitation — Use of tax losses and certain reliefs limited so taxable base cannot fall below a statutory floor (historically 1% of revenue / capped loss offset) ((approx — confirm current loss-offset cap)) (Corporate Income Tax Act (ZDDPO-2))
• Tax loss carryforward — Losses carried forward indefinitely; offset capped (historically at 50% of the tax base in a year) ((approx — confirm current cap)) (Corporate Income Tax Act (ZDDPO-2))
• Dividend participation exemption — Dividends received generally 95% exempt (5% deemed non-deductible costs), subject to conditions percent ((approx — confirm exemption mechanics)) (Corporate Income Tax Act (ZDDPO-2))
• Pillar Two global minimum tax — 15% effective minimum tax (IIR, UTPR, QDMTT) for in-scope groups; first reporting for FY2024 percent (Minimum Tax Act (ZMD))
• Withholding tax on dividends (non-residents) — 15% (may be reduced/eliminated by tax treaty or EU Parent-Subsidiary Directive) percent (Corporate Income Tax Act (ZDDPO-2))
• Withholding tax on interest (non-residents) — 15% (may be reduced/eliminated by treaty or EU Interest & Royalties Directive) percent (Corporate Income Tax Act (ZDDPO-2))
• Withholding tax on royalties (non-residents) — 15% (may be reduced/eliminated by treaty or EU Interest & Royalties Directive) percent (Corporate Income Tax Act (ZDDPO-2))
• Withholding tax — services to low-tax jurisdictions — 15% on certain service payments to jurisdictions with avg. CIT rate ≤ 12.5% on the Ministry of Finance list percent (Corporate Income Tax Act (ZDDPO-2))
• CIT return filing deadline — Within 3 months after the tax period end (31 March for calendar-year taxpayers) (Tax Procedure Act (ZDavP-2))
• Advance CIT payments — Monthly or quarterly instalments based on the prior year's assessed tax; balance due with the annual return (Tax Procedure Act (ZDavP-2))