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Slovenia Cross-Border Tax Guide

Slovenia applies withholding tax of 25% on dividends and interest (0% under EU directives for qualifying companies) and 15% on royalties (0-5% for EU). Over 60 double tax treaties provide reduced rates. Transfer pricing, CFC rules, and exit tax provisions apply in line with EU and OECD standards.

Finančna uprava RS (FURS) administers cross-border taxation. For related guidance, see our Tax Residency Guide → and Investment Income Guide →.

Withholding Tax Rates

Dividends

  • General rate: 25% on dividend distributions to non-residents.
  • EU Parent-Subsidiary Directive: 0% for qualifying corporate shareholders (≥10% holding for 24 months).
  • DTT rates: Typically 5-15% for portfolio investors; 0-5% for substantial holdings.

Interest

  • General rate: 25% on interest payments to non-residents.
  • EU Interest & Royalties Directive: 0% for qualifying associated EU companies.
  • DTT rates: Typically 0-10%.

Royalties

  • General rate: 15% on royalty payments.
  • EU Directive: 0% (or 5% in certain cases) for associated EU companies.
  • DTT rates: Typically 0-10%.

Double Tax Treaties (DTTs)

  • Slovenia has over 60 DTTs, covering all EU member states, US, Canada, China, UAE, Russia, Turkey, and many more.
  • Treaties follow the OECD Model and provide relief from double taxation through the exemption or credit method.
  • Treaty benefits must be claimed via the appropriate forms (typically a certificate of residency and a treaty relief application).

Transfer Pricing

  • Slovenia's transfer pricing rules align with OECD Transfer Pricing Guidelines and the EU's transfer pricing framework.
  • Documentation requirements apply for transactions with related parties exceeding EUR 50,000 annually.
  • The preferred methods are CUP, cost-plus, resale price, transactional net margin method (TNMM), and profit split.
  • Advance Pricing Agreements (APAs) are available through FURS.

CFC Rules

  • Slovenia implements EU ATAD CFC rules (Anti-Tax Avoidance Directive).
  • Controlled Foreign Company rules apply if a Slovenian taxpayer controls a non-EU entity with low effective taxation (less than 50% of Slovenian CIT).
  • The rules target passive income (dividends, interest, royalties, IP income) shifted to low-tax jurisdictions.

Exit Tax

  • Slovenia imposes an exit tax on unrealized capital gains when a company transfers its tax residence or assets out of Slovenia (in line with ATAD).
  • Individuals who cease Slovenian tax residency may be subject to exit tax on major shareholdings (>25%) in certain cases.

EU Directives

  • Parent-Subsidiary Directive: Elimination of WHT on dividends between associated EU companies.
  • Interest & Royalties Directive: Elimination of WHT on interest and royalty payments between associated EU companies.
  • Merger Directive: Tax-deferred restructuring across EU borders.
  • DAC6: Mandatory disclosure of cross-border tax arrangements.