OpenAccountants/Slovenia/Slovenia Corporate Income Tax

Slovenia Corporate Income Tax

Name: OpenAccountants MCP Server
Author: OpenAccountants

Source-cited draft: corporate income tax for Slovenia (tax year 2025) — rates, thresholds and rules with primary-source citations. Unverified; pending local-accountant review.

Applicable period 2025Built by Michael Cutajar and the OpenAccountants team· Last updated Jun 25, 2026

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Built by Michael Cutajar and the OpenAccountants team. Written from the official sources it cites.

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Key figures — Slovenia, 2025

Every figure is drawn from this Guide and cited to its source.

Standard CIT rate (2024-2028)

22Corporate Income Tax Act (ZDDPO-2)View source ↗

Pre-2024 standard rate

19Corporate Income Tax Act (ZDDPO-2)

Reduced rate — qualifying investment funds, pension funds, insurers

0% for certain qualifying funds/vehicles meeting statutory conditionsCorporate 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)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)Corporate Income Tax Act (ZDDPO-2)

Dividend participation exemption

Dividends received generally 95% exempt (5% deemed non-deductible costs), subject to conditionsCorporate Income Tax Act (ZDDPO-2)

Pillar Two global minimum tax

15% effective minimum tax (IIR, UTPR, QDMTT) for in-scope groups; first reporting for FY2024Minimum Tax Act (ZMD)View source ↗

Withholding tax on dividends (non-residents)

15% (may be reduced/eliminated by tax treaty or EU Parent-Subsidiary Directive)Corporate Income Tax Act (ZDDPO-2)View source ↗

Withholding tax on interest (non-residents)

15% (may be reduced/eliminated by treaty or EU Interest & Royalties Directive)Corporate Income Tax Act (ZDDPO-2)View source ↗

Withholding tax on royalties (non-residents)

15% (may be reduced/eliminated by treaty or EU Interest & Royalties Directive)Corporate Income Tax Act (ZDDPO-2)View source ↗

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 listCorporate Income Tax Act (ZDDPO-2)View source ↗

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 returnTax Procedure Act (ZDavP-2)

Rendered from the canonical facts model. General reference only — confirm with a qualified professional before acting.

The full Guide

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))

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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))