Entities established in Slovenia that form part of large multinational or domestic groups meeting the EUR 750 million revenue threshold are subject to the minimum tax regime and must comply with specific filing and reporting obligations in 2026, including the submission of domestic surtax and, where applicable, additional tax returns.
Slovenia’s Ministry of Finance has published a notice on 6 February 2026 outlining the principal reporting obligations under the Minimum Taxation Directive (2022/2523).
A person liable for minimum tax under the Minimum Tax Act (Official Gazette of the Republic of Slovenia, No. 131/23) is an entity that is located in the Republic of Slovenia and is part of an international group of companies or a large domestic group whose annual revenues amount to at least EUR 750 million in at least two of the four reporting financial years preceding the test financial year.
Obligations of taxpayers under Articles 62, 65, and 66 of the ZMD
All persons liable for the minimum tax are required to comply with the obligations set out in Articles 62, 65, and 66 of the ZMD.
Obligation to submit a domestic surtax return
All persons liable for the minimum tax are obliged to submit a domestic surtax return, regardless of whether there is an obligation to pay domestic surtax for a particular business year.
The return must be submitted via the eDavki portal. The submission deadline is 30 June 2026 if the financial year ended on or before 31 December 2024.
The form is expected to be available for filing on eDavki in May 2026. The designated filing entity must submit a return for all entities within the group in Slovenia, and all entities in the group are jointly and severally liable for the payment of the entire domestic surtax liability.
Information form for calculating the surtax
If the taxpayer does not submit the information form for calculating the surtax to the Financial Administration by 30 June 2026, the taxpayer must provide, in the domestic surtax calculation, information regarding the group entity that has submitted an information form to the Financial Administration of the Republic of Slovenia or whose information form will be received by the Financial Administration from the competent authorities of another country.
It must also be stated whether the entity is a designated local entity (an entity located in the Republic of Slovenia) or an investor entity, as defined in the third paragraph of Article 65 of the ZMD.
Obligation to submit an additional tax return
The additional tax calculation must be submitted by 30 July 2026 only if the taxpayer is required, in accordance with the provisions of the ZMD or based on the rules on the inclusion of income or the rules on undertaxed profits, to calculate additional tax.
