On 28 May 2019, the Slovenian Parliament has approved the EU Directive on the mandatory disclosure and exchange of cross-border tax arrangements (DAC6). The final Slovenian Mandatory Disclosure Rules legislation is significantly aligned to the requirements of the Directive. The rules were published in the Official Gazette of on 7 June 2019 and entered into force on 22 June 2019.

The scope of taxes covered under the Slovenian final legislation is fully aligned with the Directive and applies to all taxes except VAT, customs duties, excise duties and compulsory social security contributions.

Under the Directive, reporting starts from 1 July 2020 and exchanges between jurisdictions from 31 October 2020. However, reports will retroactively cover arrangements where the first step is implemented between 25 June 2018 and 1 July 2020. The Slovenian reporting deadlines are aligned with DAC6.

Failure to comply with the DAC6 reporting requirements can result in monetary penalties for intermediaries or relevant taxpayers. Non-compliance penalties can be imposed up to a maximum of €15,000 for small companies and up to a maximum of €30,000 for medium and large-sized companies. In addition, the “responsible person” of the legal entity which is the relevant taxpayer or intermediary may also be subject to penalties up to €4,000. For serious offenses, higher penalties may apply up to a maximum of €100,000 for small companies and €150,000 for larger companies. Serious offense penalties up to €20,000 can also be imposed on the “responsible person” of the legal entity which is the relevant taxpayer or intermediary.