Head of practice
Head of Corporate Law and Fintech Practice. Expert in the creation and reorganization of companies, support of M&A transactions, as well as legal support for opening and running a business in the EU, Asia, and North America.
Tax structuring in Slovenia
Slovenia continues to be an attractive jurisdiction for doing business in the European Union, offering a stable legal system and a competitive tax environment. The article reveals the features of tax structuring in Slovenia as of October 2025, taking into account the latest changes in legislation.
Current tax system of Slovenia
Corporate Tax
From 2024, Slovenia has introduced important changes to corporate taxation. The standard corporate tax rate has been increased from 19% to 22% for the period 2024-2028 in accordance with the Corporate Income Tax Act (ZDDPO-2). These changes are regulated by the amendment ZDDPO-2U, adopted by the Parliament on 27 November 2024.
The tax base is calculated on the basis of the company’s profit, taking into account allowable expenses in accordance with the provisions of Article 60 of the ZDDPO-2 Act. Taxpayers are obliged to calculate and pay corporate tax in accordance with the Corporate Income Tax Act and applicable regulations.
Value Added Tax (VAT)
The standard VAT rate in Slovenia is 22%, which is in line with European standards. Reduced rates: 9.5% for certain categories of goods and services and 5% for specific cases. Important changes have been introduced since January 2025: beverages with added sugar or sweeteners are now taxed at the standard rate of 22% instead of the reduced rate of 9.5%.
Tax planning and optimization
Investment incentives
Slovenia is actively developing investment tax incentives. In November 2024, tax breaks were extended for corporate taxpayers investing in digital transformation and ecological transition. These measures are aimed at stimulating innovation and sustainable development.
Avoidance of Double Taxation
Ukraine and Slovenia have concluded a Convention on the Avoidance of Double Taxation, which guarantees fair taxation of citizens of one country in the territory of the other. The Convention applies to taxes on income and capital and is an important tool for Ukrainian investors in Slovenia. Slovenia has over 55 active agreements on the avoidance of double taxation with various countries.
Business structuring for foreign investors
Legal Forms
Slovenia offers various legal forms of doing business. The most popular is the limited liability company (d.o.o.), which provides flexibility in structuring and limited liability of participants.
Tax benefits of residency
Residents of Slovenia are subject to unlimited tax liability, but the system offers opportunities for optimization through the correct structuring of transactions and the use of international agreements.
Recent legislative changes
Important amendments to the Tax Procedure Act and the Corporate Tax Act entered into force in 2025. The rules for collecting VAT have been changed and stricter measures have been introduced for systematic violators of reporting deadlines.
According to the 2025 amendments, restrictions on tax loss carryforwards and new restrictions on interest deductions have been introduced. A 5-year limitation on the carryforward of excess VAT has also been introduced.
Practical tax planning tips
International structuring
When planning international transactions, it is important to consider the specifics of the application of double taxation agreements and transfer pricing rules in the context of Slovenian law.
VAT optimization
Correct determination of the place of supply of goods and services, as well as the use of the correct VAT code, are critical for optimizing tax liabilities. Slovenia has introduced a VAT grouping system, which can provide additional opportunities for large holding structures.
Slovenia continues to adapt its tax legislation to European standards and the requirements of modern business. Despite the increase in the corporate tax rate to 22%, the country remains attractive due to the stability of the legal system, EU membership and a developed network of international tax agreements.
Successful tax structuring in Slovenia requires a professional approach, taking into account all current changes in legislation and the specifics of your business.
Why should you contact the law firm “Prikhodko & Partners”?
The law firm “Prykhodko & Partners” specializes in international tax planning and business structuring in European jurisdictions. Our experts have in-depth knowledge of Slovenian tax legislation and practical experience working with international clients.
We provide comprehensive services in:
- Company registration in Slovenia
- Tax planning and optimization
- International business structuring
- Support for cross-border transactions
- Compliance with the requirements of Ukrainian and Slovenian legislation
By contacting “Prikhodko & Partners”, you get a reliable partner who will ensure maximum tax efficiency and full compliance with the legislation. Our team guarantees an individual approach to each client and the best solutions for your business.
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