Slovenia: Amendments to tax procedure law, amendments and clarifications to corporate income tax law

Amendments to the Tax Procedure Law were (published in the gazette on November 22, 2024, and effective November 27, 2024) aim to:

• Address the unconstitutionality identified by the Constitutional Court regarding tax avoidance by introducing a new article that outlines the legal consequences for prior taxpayer actions and administrative decisions
• Align national legislation with EU directives
• Comply with updated substantive provisions of the Income Tax Act
• Incorporate necessary changes identified during application of the current law

In addition, amendments to the Corporate Income Tax Law were approved by Parliament on November 27, 2024, removing special rules for tax base calculation using standardized costs and interest limitation rules, effective January 1, 2025.

Finally, the tax authorities on October 11, 2024, clarified that eligibility for tax reliefs for investments under the Corporate Income Tax Law depends on whether the asset is classified as equipment in the company's accounting records, with detachable equipment qualifying and permanently integrated items not qualifying.

For further information, contact a KPMG tax professional in Slovenia:

Darinka Hvala | darinka.hvala@kpmg.si