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8.7.1 Direct Taxes on Income Residents
8.7.1.1 Interest
8.7.1.1.1. Taxation of Corporations
Interest payments resulting from the Securities by:
(a) a legal person resident for taxation purposes in the Republic of Slovenia; or
(b) a permanent establishment (poslovna enota) in the Republic Slovenia of a legal person not resident
for taxation purposes in the Republic of Slovenia;
are subject to Slovenian Corporate Income Tax (davek od dohodkov pravnih oseb) as a part of the overall
income of such resident or, as the case may be, a permanent establishment in the Republic of Slovenia of a
resident for taxation purposes outside the Republic of Slovenia.
No Slovenian withholding tax will be levied on payments under the Securities to legal persons regardless of
their residence for taxation purposes, if the recipient of the payment provides the payer of the interest with his
Slovenian tax number.
Slovenian Corporate Income Tax is levied at a flat rate of 21%. As of 2010, the corporate income tax rate will
be reduced to 20%.
8.7.1.1.2. Individuals
Under the Slovenian tax laws currently in effect, the payment of interest from Securities, as defined in Art. 81
of the Slovenian Personal Income Tax Act (Zakon o dohodnini), in accordance with their terms and conditions
to a resident individual, within the meaning of the relevant provisions of the Slovenian Personal Income Tax
Act, will generally be subject to Slovenian income tax at a flat rate of 20%, levied by way of withholding or
by way of assessment, provided that these qualify as non-business assets.
The tax base shall be obtained interest unless otherwise provided by law. The tax base on interest resulting
from the disposal of discounted debt securities prior to maturity of the security or upon purchase of the discounted
debt security prior to or upon maturity of the paper shall be the interest calculated for the period from
the day of acquisition to the day of disposal or purchase of the discounted debt security. Discounted debt securities
shall also include non-coupon debt securities.
The level of interest shall be determined according to the methodology of constant yield. If in a particular
financial debt arrangement it is not explicitly determined in advance what share of individual payment represents
repayment of the principal and what share is the interest, it shall be deemed for the purpose of taxation
that interest calculated at the recognised interest rate, as defined in the Corporate Income Tax Act, is paid out
first.
If interest is paid out by a Slovenian tax payer, then such payments are subject to the Slovenian tax payer
calculating, withholding and paying withholding tax on the interest in amount of 20%.
If withholding tax is deducted from the interest in Austria, Belgium or Luxembourg under the local provisions
implementing the EU Savings Directive, the resident individual may claim a credit of the tax deducted abroad
against his/her Slovenian income tax liability.
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