On 21 December 2023, Slovenia released the Minimum Tax Act No.131 of 22 December 2023 through the Official Gazette, outlining the adoption of the Pillar 2 global minimum tax as per the guidelines of Council Directive (EU) 2022/2523. The law applies a minimum tax rate of 15% to MNE groups with annual consolidated revenue exceeding €750 million in at least two of the past four fiscal years. Adhering to the Directive and OECD Model Rules, the regulations establish an Income Inclusion Rule (IIR), Undertaxed Profit Rule (UTPR) and qualified domestic top-up tax (QDTT).
The Minimum Tax Act became effective on 23 December 2023, and is typically applicable to financial years commencing on or after 31 December 2023. However, the UTPR provision is applicable to financial years commencing on or after 31 December 2024.
