United States-Slovenia Tax Treaty

Slovenia International Tax Compliance Rules

Quick Summary. Nestled in Central Europe along the Adriatic Sea and strategically located between the Balkans and Western Europe, the Republic of Slovenia is a mountainous country with deep cultural roots.  

Part of the Austro-Hungarian Empire until the end of World War I, the Slovene lands subsequently comprised Yugoslavia in 1929. The Slovenes established independence in 1991 and began a post-communist transition.

Slovenia is a member of both NATO and the EU, as well as the OECD and World Trade Organization.

Slovenia has three levels of regulatory authority: supra-national, national, and sub-national (municipalities).

The executive branch is made of a President, Prime Minister, and Council of Ministers.  

The legislative branch is comprised of a bicameral Parliament: The National Council or Drzavni Svet and the National Assembly or Drzavni Zbor.  

The judicial branch consists of a Supreme Court and Constitutional Court and consists of a five-tier (district, regional, appeals, supreme, and administrative) court system. Slovenia has a well-developed, independent legal system.

Slovenia taxes residents on worldwide income, sourced both in and outside of Slovenia.

U.S.-Slovenia Tax Treaty

Non-residents are subject to tax only on income sourced in Slovenia.

Slovenia Tax Treaty

•  Convention Between the United States of America and the Republic of Slovenia for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, signed at Ljubljana on June 21, 1999
• Technical Explanation of the Convention between the United States and the Republic of Slovenia signed on June 21, 1999

Currency.  Euro (EUR)

Common Legal Entities.  Limited and unlimited liability company, limited partnership, public limited liability company, Societas Europaea,  partnership limited by share, branches.  

Tax Authorities.  Ministry of Finance, Financial Administration of the Republic of Slovenia

Tax Treaties.  Slovenia is party to 59 tax treaties, and is a signatory to the OECD MLI.  

Slovenia has signed bilateral taxation treaties with: Albania, Armenia, Austria, Azerbaijan, Belarus, Belgium, Bosnia and Herzegovina, Bulgaria, Canada, China, Croatia, Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Georgia, Germany, Greece, Hungary, Iceland, India, Iran, Ireland, the Isle of Man, Israel, Italy, Kazakhstan, Kosovo, Kuwait, Latvia, Lithuania, Luxembourg, Macedonia, Malta, Moldova, Montenegro, the Netherlands, Norway, Poland, Portugal, Qatar, the Republic of Korea, Romania, the Russian Federation, Serbia, Singapore, Slovakia, Spain, Sweden, Switzerland, Thailand, Turkey, Ukraine, the United Arab Emirates, the United Kingdom, the United States, and Uzbekistan.

Corporate Income Tax Rate.  19%

Individual Tax Rate.  Up to 50%

Corporate Capital Gains Tax Rate.  19%, special rules may apply.  

Individual Capital Gains Tax Rate.  27.5%

Residence.  Based upon formal residence tie or an actual residence tie.  

Withholding Tax.

            Dividends. 27.5% (individual resident) / 15% (company nonresident) / 27.5% (individual nonresident)

            Interest. 27.5% (individual resident) / 15% (company nonresident) / 27.5% (individual nonresident)

            Royalties.  25% (individual resident) / 15% (company nonresident) / 25% (individual nonresident)

Transfer Pricing.  Standards based upon arm’s length terms.  

CFC Rules.  Provides for rules based upon the EU Anti-Tax Avoidance Directive.  

Hybrid Treatment.  Provides for rules based upon hybrid mismatch rules/EU Anti-Tax Avoidance Directive.  

Inheritance/estate tax.  Progressive rates.  

Tax Treaty Network – International Tax Attorneys

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