Slovenia revised its Corporate Income Tax Act, introducing new rules for asset transfers and investment funds for 2026.
Slovenia has amended its Corporate Income Tax Act (ZDDPO-2V), with the changes published in the Official Gazette No. 85/2025 on 6 November 2025.
The revisions introduce new provisions for investment funds and clarify rules for asset transfers and divisions during corporate restructurings. Key updates include revised definitions of “enterprise” and “operating unit,” as well as changes to the tax treatment of distributed profits and certain types of income for investment funds.
The amendments aim to prevent situations where income, such as rent or interest, is deductible for the payer but not taxed for the investor. They also reduce the minimum profit distribution required for 0% taxation from 90% to 75% and exclude unrealised gains from the calculation, creating a more practical and balanced framework.
The law will take effect on 21 November 2025 and apply to tax periods beginning 1 January 2026.
