Slovenia’s Financial Administration has set out key reporting requirements and June and July 2026 filing deadlines for minimum tax and top-up tax returns under the ZMD.

Slovenia’s Financial Administration has issued a notice on 6 February 2026 outlined key reporting obligations for taxpayers subject to the minimum tax under the Minimum Tax Act (ZMD). ZMD primarily refers to the Draft Law on Minimum Tax, designed to ensure a minimum 15% effective tax rate for large multinational and domestic groups. It represents a separate, specialized corporate tax legislation.

Scope of the minimum tax

Under the Minimum Tax Act (Official Gazette of the Republic of Slovenia, No. 131/23), a taxpayer is any entity within a group that is located in the Republic of Slovenia and forms part of an international corporate group or a large domestic group with annual revenues of at least EUR 750 million in at least two of the four reporting fiscal years preceding the test fiscal year.

Domestic top-up tax return

Pursuant to Articles 62, 65, and 66 of the ZMD, all taxpayers subject to the minimum tax are required to submit a domestic top-up tax return, irrespective of whether a domestic top-up tax liability arises for the relevant fiscal year.

The return must be filed via the eDavki portal. For fiscal years ending on or before 31 December 2024, the filing deadline is 30 June 2026. The Financial Administration expects the relevant form to be available in eDavki in May 2026.

The ZMD allows a filing entity to submit the domestic top-up tax return on behalf of all group entities located in Slovenia. In such cases, all Slovenian group entities are jointly liable for payment of the full domestic top-up tax obligation.

Informative form requirements

Where a taxpayer does not itself submit the informative form for the top-up tax return to the Financial Administration by 30 June 2026, the domestic top-up tax return must include details of the group entity that will either submit the informative form directly to the Financial Administration of the Republic of Slovenia or provide it through the competent authorities of another country.

Taxpayers must indicate whether the relevant entity is a designated local entity located in Slovenia or a filing entity, as defined in the third paragraph of Article 65 of the ZMD.

Top-up tax return obligation

A top-up tax return must be filed by 30 July 2026 only where the taxpayer is required to calculate the top-up tax under the provisions of the ZMD, including cases arising from the income inclusion rule or the undertaxed profits rule.

Further guidance

The Financial Administration has made answers to basic questions on minimum tax liability and reporting obligations available through its chatbot. Queries can also be sent to minimalni-davek.fu@gov.si. Additional guidance is published in the “Minimum Tax” section and in the document Top-up Tax – General and Procedural Provisions on the Financial Administration’s website.