Slovenia’s government has presented a draft bill (EVA: 2024-1611-0039) to the parliament on 25 October 2024, proposing several amendments to the corporate income tax law.
Tax loss carry-forward limitation
The bill suggests limiting the carry-forward of business tax losses to five years and seven years for existing losses. Currently, the tax loss carry-forward has an unlimited time frame.
Carry-forward of unused allowance
The bill allows the carry-forward of unused digital and green transition allowances for five years. This bill, introduced on 1 January 2022, supports qualified investments in technology such as cloud computing and artificial intelligence (AI), energy efficiency, decarbonisation, and big data.
Interest deduction limitation
The bill suggests removing the thin capitalisation rule that limits interest deductions when the debt-to-equity ratio exceeds 4:1 and raising the interest deduction limit threshold from EUR 1 million to EUR 3 million.
Other amendments
- Introducing the definition of “personal data breach” as outlined in the Directive on Administrative Cooperation (2011/16) (DAC);
- Mandating the competent authority to automatically share information about income earned through digital platforms;
- Establishing the legal foundation for implementing reporting obligations under the OECD Model Rules on Mandatory Disclosure;
- Introducing procedures for calculating income tax on non-cash income from company shares when grossing-up is waived;
- Shorten the tax return filing deadline from 60 to 30 days after a request by the tax authority;
- Introducing electronic document service for taxpayers who have submitted tax calculations, returns, or applications via the eTaxes system;
- Introducing new penalties for submitting incorrect tax return information and providing falsified, inaccurate, or incomplete information related to bank accounts and financial instruments;
- Introducing provisions for designating authorities for automatic data exchange, international information sharing, tax collection assistance, mutual agreement procedures (MAPs), and eliminating the statute of limitations on tax assessments during MAPs.
