At a glance
#Dates are for an example year end of Dec 31, 2025. Where local law moves a deadline on a weekend or national public holiday to the next working day, the date shown is already moved. Use the Deadlines tool for your own year end and thresholds.
Verified 2026-10-27. Tax authority: Finančna uprava Republike Slovenije (FURS, Financial Administration of the Republic of Slovenia). Summaries are simplified; check the linked official source before relying on them.
The law
#Slovenia sets the arm's length rule in Articles 16 and 17 of the Corporate Income Tax Act (ZDDPO-2). Article 16 covers deals with foreign related parties: income counts at no less than, and expenses at no more than, the comparable market price (art. 16(3) and (4)). Related means a stake of at least 25% in capital, management, control or votes, control by contract, or deal terms that differ from those between unrelated parties (art. 16(1)). Article 17 covers deals between resident related parties, and there the tax base only changes if one side has an unused tax loss, pays tax at 0% or a lower special rate, or is exempt (art. 17(6)). Article 19 caps interest on related party loans at a recognised rate, which the finance minister publishes before each tax year. The Rules on transfer prices (Official Gazette 141/06 and 4/12) give the detail, and FURS follows the OECD Guidelines as an interpretation aid.
Documentation
#Every taxpayer that deals with related parties must keep a master file and a local file (ZDavP-2 art. 382(1)). The law sets no revenue or transaction size threshold. The files must be prepared on an ongoing basis, and at the latest when the corporate income tax return is filed (art. 382(2)). They are not filed with the return, but the return carries transfer pricing annexes 15, 16 and 17. In a tax audit the files should be handed over at once, or within a deadline of 30 to 90 days set by the tax office (art. 382(5)). A master file that is not in Slovenian must be translated within a deadline of at least 60 days (art. 382(7)). The files must be kept for 10 years after the year they cover (art. 382(6)). For deals between two Slovenian residents, only data on the market price must be shown, and only when the tax office asks in an audit (ZDDPO-2 art. 18(2)).
Methods
#Art. 16(5) lists five methods: comparable uncontrolled price, resale price, cost plus, profit split and net profit margin (TNMM). The most appropriate method for the case must be used. Internal comparables are preferred to external ones. If a traditional method and a profit method are equally reliable, the traditional method wins, and the comparable uncontrolled price method comes before the others (Rules art. 1.a). If data is reliable, the value in the range that best fits the deal is used. If data is less reliable, the interquartile range applies and the median may be used (Rules art. 21, as amended in 2012).
Penalties
#Failing to give the documentation, or giving it late or wrongly, is a tax offence under ZDavP-2 art. 397(1). The fine is EUR 1,200 to 15,000 for a company, and EUR 3,200 to 30,000 for a medium or large company. The responsible person can be fined EUR 600 to 4,000, or EUR 800 to 4,000 at a medium or large company. The same fines apply to a missing or late country-by-country report and to a missing or late corporate income tax return. These amounts come from the 2020 consolidated text and were not checked against later changes. Minimum tax offences carry fines of EUR 3,200 to 100,000 for a company and EUR 800 to 4,000 for the responsible person (ZMD art. 70).
Pillar Two
#The Minimum Tax Act (Zakon o minimalnem davku, ZMD, Official Gazette 131/2023) is in force. It covers the income inclusion rule (arts. 9 to 14) and the domestic top-up tax, called the QDMTT (arts. 55 to 64), for fiscal years that begin on or after 31 December 2023. The undertaxed profits rule (arts. 15 and 16) applies to fiscal years that begin on or after 31 December 2024 (art. 76). The scope is groups with revenue of at least EUR 750m in two of the four prior years (art. 6). Each entity files the domestic top-up tax return and the GloBE information return within 15 months of year end, or within 18 months for the transition year (arts. 62, 65 and 73). A top-up tax return under the income inclusion or undertaxed profits rule is due 30 days after that (art. 66), and tax is paid 30 days after filing.
Other rules
#The corporate income tax return is due three months after the tax year, so 31 March for a calendar year (ZDavP-2 art. 358). It is filed through eDavki. The general rate is 19%, but FURS says 22% applies for 2024 to 2028. The balance due after filing is paid within 30 days of the legal filing date, so by 30 April for a calendar year. Groups with revenue of at least EUR 750m file a CbC report within 12 months of year end if the ultimate parent is resident in Slovenia, or in some cases through a Slovenian group member (ZDavP-2 art. 255.i). Every Slovenian member of such a group files a CbC notice with its return (Rules on ZDavP-2 art. 86.e). Unilateral, bilateral and multilateral APAs (ZDavP-2 arts. 14.a to 14.g) and the mutual agreement procedure are available.
Filings and deadlines
#| # | Filing | When | Who | Source |
|---|---|---|---|---|
| 1 | Corporate income tax return (obračun davka od dohodkov pravnih oseb, DDPO) Due three months after the end of the tax year (ZDavP-2 art. 358(2) and (3)), so 31 March 2026 for 2025 as FURS confirms. Any tax still due is paid within 30 days of that legal deadline, so by 30 April for a calendar year (ZDavP-2 art. 370(2), as amended from 1 January 2026). No standing extension was found. Under ZDavP-2 art. 45(2) a deadline that falls on a Sunday, a public holiday or another day the authority does not work moves to the next working day. | 3 months after year end (e.g. Mar 31, 2026) | All taxpayers of Slovenian corporate income tax. The return is filed only electronically through eDavki. | ZDavP-2 art. 358 and art. 45, and FURS corporate income tax page |
| 2 | Transfer pricing annexes in the corporate income tax return (Priloga 15, 16 and 17) Filed inside the return, so it follows the return deadline. Annex 15 covers loans between related parties, annex 16 transfer pricing data on deals under art. 16, and annex 17 deals between resident related parties under art. 17. Price adjustments go into annex 1 of the return. Under ZDavP-2 art. 45(2) a deadline on a non-working day moves to the next working day. | With Corporate income tax return (obračun davka od dohodkov pravnih oseb, DDPO) (e.g. Mar 31, 2026) | Taxpayers that tick on the return that they deal with related persons under art. 16 or art. 17 ZDDPO-2. No size threshold was found. | FURS guidance on transfer prices (3rd edition, January 2025) |
| 3 | Master file (splošna dokumentacija, masterfile) Must be prepared on an ongoing basis and at the latest when the return is filed (ZDavP-2 art. 382(2)), so by the return due date. It is not filed. In a tax audit it must be handed over at once, or within 30 to 90 days if the tax office sets a deadline (art. 382(5)). If it is not in Slovenian it must be translated within a deadline of at least 60 days (art. 382(7)). Keep it for 10 years (art. 382(6)). Shown without a weekend move, because the file is prepared and not filed. | With Corporate income tax return (obračun davka od dohodkov pravnih oseb, DDPO) (e.g. Mar 31, 2026) | Every taxpayer that deals with related persons. The law sets no revenue or transaction threshold. It may be one document for the whole group. | ZDavP-2 art. 382 (PISRS) |
| 4 | Local file (posebna dokumentacija, country-specific documentation) Must be prepared on an ongoing basis and at the latest when the return is filed (ZDavP-2 art. 382(2)). It is not filed, but must be handed over on request in a tax audit, at once or within 30 to 90 days (art. 382(5)). Keep it for 10 years (art. 382(6)). The fine for missing documentation is EUR 1,200 to 15,000, or EUR 3,200 to 30,000 for a medium or large company (art. 397(1)). Shown without a weekend move, because the file is prepared and not filed. | With Corporate income tax return (obračun davka od dohodkov pravnih oseb, DDPO) (e.g. Mar 31, 2026) | Every taxpayer that deals with related persons, for each related transaction or for similar transactions grouped together. The law sets no revenue or transaction threshold. For deals between two Slovenian residents, only market price data is needed, and only on request in an audit (ZDDPO-2 art. 18(2)). | ZDavP-2 art. 382 and art. 397 (PISRS) |
| 5 | CbC notification (Obvestilo CbCR) Filed electronically at the same time as the corporate income tax return (Rules on ZDavP-2 art. 86.e(2)), so it follows the return due date. It says whether the entity is the ultimate parent, a surrogate parent or the reporting entity, who the reporting entity is, and whether the entity can get the data from the ultimate parent. The form is on the FURS website. ZDavP-2 art. 397(1) fines a missing or late CbC report; it does not name the notice itself. Under ZDavP-2 art. 45(2) a deadline on a non-working day moves to the next working day. | With Corporate income tax return (obračun davka od dohodkov pravnih oseb, DDPO) (e.g. Mar 31, 2026) | Every Slovenian taxpayer that is a constituent entity of a group with consolidated revenue of at least EUR 750m in the year before the reporting year, if the group has entities in more than one tax jurisdiction. | FURS CbCR page and Rules on ZDavP-2 art. 86.e (Official Gazette 30/17) |
| 6 | Country-by-country report (poročilo po državah, CbCR) Filed by the reporting entity within 12 months of the last day of the group's reporting year (ZDavP-2 art. 255.i(2)), through the FURS B2B channel. FURS lists 31 December 2026 for the 2025 reporting year. The report cannot be used by the tax office to adjust transfer prices (art. 255.k(2)). A late, wrong or missing report can be fined under ZDavP-2 art. 397(1). Under ZDavP-2 art. 45(2) a deadline on a non-working day moves to the next working day. | 12 months after year end (e.g. Dec 31, 2026) | Ultimate parent company that is resident in Slovenia, or a Slovenian constituent entity or surrogate parent that must file under Directive 2016/881/EU, for groups with consolidated revenue of at least EUR 750m. | ZDavP-2 art. 255.i (PISRS) and FURS CbCR page |
| 7 | Domestic top-up tax return (obračun domačega povrhnjega davka, GloBE-ODPD) Every Slovenian constituent entity must file it, even if no domestic top-up tax is due, within 15 months after the reporting year (ZMD art. 62(1)). The entities may appoint one filing entity to file for all (art. 62(2)). FURS says the first return for calendar 2024 is due 30 June 2026. The 18 month period belongs to the group's transition year, which is the first year the group is in scope of the Act for Slovenia (art. 72(1)). This file applies it to year ends up to 30 December 2025. A group that came into scope later has its own transition year, which this tool cannot tell. Under ZDavP-2 art. 45(2), a deadline on a Sunday, a public holiday or another day the tax office does not work (in practice also a Saturday) moves to the next working day. | 15 months after year end (e.g. Mar 31, 2027) | Slovenian group members (or the one local entity they designate) of groups with consolidated revenue of at least EUR 750m in at least two of the four fiscal years before the tested year (ZMD art. 6(1)). | ZMD arts. 62, 72 and 73 (Official Gazette 131/2023) and FURS notice of 6 February 2026 |
| 8 | GloBE information return (informativni obrazec za obračun povrhnjega davka, GloBE-GIR) Filed within 15 months after the reporting year (ZMD art. 65(1)). The data must be true, correct and complete. A designated local entity may file for all Slovenian entities (art. 65(2)). FURS says the GIR for calendar 2024 is due 30 June 2026. The 18 month period belongs to the group's transition year, which is the first year the group is in scope of the Act for Slovenia (art. 72(1)). This file applies it to year ends up to 30 December 2025. A group that came into scope later has its own transition year, which this tool cannot tell. Under ZDavP-2 art. 45(2), a deadline on a Sunday, a public holiday or another day the tax office does not work (in practice also a Saturday) moves to the next working day. | 15 months after year end (e.g. Mar 31, 2027) | Slovenian group members (or the one local entity they designate) of groups with consolidated revenue of at least EUR 750m in at least two of the four fiscal years before the tested year (ZMD art. 6(1)). Not needed if the ultimate parent or a designated filing entity files it in a state that has a qualifying competent authority agreement with Slovenia. | ZMD arts. 65 and 73 (Official Gazette 131/2023) |
| 9 | Notice of the designated local entity or of the entity filing the GIR abroad A designated local entity tells the tax office it was designated, and an entity relying on a foreign filing names the filer and the country, both within the GIR deadline (ZMD art. 65(2) and (3)). Failure can be fined under art. 70(1) point 3. Under ZDavP-2 art. 45(2), a deadline on a Sunday, a public holiday or another day the tax office does not work (in practice also a Saturday) moves to the next working day. | With GloBE information return (informativni obrazec za obračun povrhnjega davka, GloBE-GIR) (e.g. Mar 31, 2027) | Slovenian constituent entities whose GIR is filed by a designated local entity in Slovenia, or by the ultimate parent or a designated filing entity abroad under a qualifying competent authority agreement. | ZMD art. 65(2) and (3) (Official Gazette 131/2023) |
| 10 | Domestic top-up tax payment The domestic top-up tax is paid within 30 days of filing the return (ZMD art. 62(4)). The date shown is the latest date if the return is filed on its last day. Joint liability applies to all Slovenian group members if a filing entity files (art. 62(5)). A late payment can be fined under art. 70(1). The 18 month period belongs to the group's transition year, which is the first year the group is in scope of the Act for Slovenia (art. 72(1)). This file applies it to year ends up to 30 December 2025. A group that came into scope later has its own transition year, which this tool cannot tell. Under ZDavP-2 art. 45(2), a deadline on a Sunday, a public holiday or another day the tax office does not work (in practice also a Saturday) moves to the next working day. | 15 months after year end, plus 30 days (e.g. Apr 30, 2027) | Slovenian group members (or the one local entity they designate) of groups with consolidated revenue of at least EUR 750m in at least two of the four fiscal years before the tested year (ZMD art. 6(1)). | ZMD art. 62(4) and (5) (Official Gazette 131/2023) |
| 11 | Top-up tax return under the income inclusion or undertaxed profits rule (obračun povrhnjega davka) Due 30 days after the GIR deadline (ZMD art. 66(1)), and the tax is paid 30 days after filing (art. 66(3)). FURS gave 30 July 2026 for the 2024 reporting year. If the return is filed on its last day, payment is due 30 days later again. The 18 month period belongs to the group's transition year, which is the first year the group is in scope of the Act for Slovenia (art. 72(1)). This file applies it to year ends up to 30 December 2025. A group that came into scope later has its own transition year, which this tool cannot tell. Under ZDavP-2 art. 45(2), a deadline on a Sunday, a public holiday or another day the tax office does not work (in practice also a Saturday) moves to the next working day. | 15 months after year end, plus 30 days (e.g. Apr 30, 2027) | Only Slovenian entities that owe top-up tax under the income inclusion rule (IIR) or the undertaxed profits rule (UTPR). The UTPR applies to fiscal years that begin on or after 31 December 2024 (ZMD art. 76(2)). | ZMD art. 66 and FURS notice of 6 February 2026 |
Official texts
#- Corporate Income Tax Act (ZDDPO-2), Rules on transfer prices, Tax Procedure Act (ZDavP-2) and its Rules, and Minimum Tax Act (ZMD) (PISRS and Uradni list RS) (Not protected by copyright: official texts from the legislative, administrative and judicial fields are not protected (Art. 9(1) point 2 of the Copyright and Related Rights Act, ZASP). Translations are protected unless published as official texts, so the English in the Assistant is the site's own unofficial translation.)