New Zealand has published an order providing for the ratification of its first income tax treaty with Slovenia. The agreement sets withholding tax limits of 5% or 15% on dividends and 10% on interest and royalties, with provisions taking effect after the treaty enters into force.
New Zealand has published the Double Tax Agreements (Republic of Slovenia) Order 2026, providing for the ratification of its income tax treaty with Slovenia on 24 August 2026.
Signed on 3 December 2024, the treaty aims to prevent double taxation, reduce tax evasion and avoidance, and provide greater certainty for cross-border payments.
The New Zealand–Slovenia tax treaty caps withholding tax at 5% on qualifying dividends where a company directly holds at least 10% of the paying company for 365 days, and 15% on other dividends. Interest and royalties are generally subject to a 10% withholding tax cap, although exemptions may apply to qualifying government, central bank, and loan-related interest recipients. Royalties cover payments for the use of intellectual property, certain media, commercial or scientific information, and related assistance.
The treaty will enter into force once the two countries exchange their instruments of ratification. Its withholding tax provisions will apply from the first day of the third month following its entry into force.
