Slovenia: Proposed amendments to income tax law
A draft bill proposing amendments to corporate income tax law has been submitted to Parliament
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November 20, 2024
Slovenia's government submitted to the Parliament a draft bill proposing amendments to the corporate income tax law including:
- Tax loss carry-forward: The bill proposes a limitation of the possibility to carry forward tax losses from business activities to five years and to seven years for tax losses that have already accrued (currently the Slovenian law provides for an unlimited tax loss carry forward).
- Carry-forward of unused allowance: The bill proposes the introduction of the possibility to carry forward to the next five years the portion of the unused digital and green transition allowance. The allowance for qualifying investments (e.g., in cloud computing, artificial intelligence, big data, energy efficiency, decarbonisation) was introduced as from January 1, 2022, and reduces the tax base up to a maximum of the taxpayer’s tax base.
- Interest deduction limitation: The bill proposes the elimination of the current thin capitalisation rule, which denies the deduction of interest expenses where the debt-to-equity ratio exceeds 4:1. In addition, the bill proposes an increase of the de minimis threshold in relation to the interest deduction limitation rule (implemented as part of the ATAD transposition) from €1 million to €3 million.
Read a November 2024 report prepared by KPMG's EU Tax Centre