Tax News, April 2025

In the April edition of our tax news, we inform you that the Slovenian Financial Administration (FURS) began issuing the first batch of informative personal income tax calculations for the year 2024 on 31 March 2025. We highlight a significant ruling by the Supreme Court regarding the treatment of loans between related parties, which is expected to have a notable impact on future tax practices. Additionally, we report on the introduction of new reciprocal tariffs on imports of goods into the United States and recent developments concerning crypto-assets and derivative financial instruments. Finally, we present the latest 2025 EY Law Study.

SLOVENIAN TAX AUTHORITIES ISSUED THE FIRST BATCH OF INFORMATIVE TAX CALCULATIONS FOR YEAR 2024 ON 31 MARCH 2025.

The Informative Tax Calculation is assembled according to the information available to the Tax Authorities based on official records, data on the income and dependent family members, which were reported to the Tax Authorities by payers of the income and individuals during the year.

The individual must carefully review the Informative Tax Calculation. If the individual does not agree with the tax calculation or finds that the given data is incorrect or incomplete, they must file an objection against Informative Tax Calculation and submit it to the competent tax office that issued the calculation no later than 30 days (15 days from received Informative Tax Calculation which is considered as received after 15 days from the dispatch) from the date the calculation was issued. Deadline for submitting objection is 30 April 2025. If the individual agrees with the data included in the calculation and finds that it is correct, no further action is needed. In such case, after the expiry of the deadline for filing an objection, the Informative Tax Calculation is considered as their final Annual income tax assessment for tax year.

Deadline for additional tax payment is 30 May 2025. Refund of overpaid tax should be transferred by 30 May 2025. 

Second batch of Informative Tax Calculation is planned to be issued on 30 May 2025.

SUPREME COURT RULING REGARDING THE TREATMENT OF LOANS BETWEEN RELATED PARTIES

The Supreme Court of the Republic of Slovenia issued an important ruling regarding loans between related parties, case no. X Ips 27/2024, on February 12, 2025. The Supreme Court ruled that in the case of a loan relationship between a legal entity as the lender and a related individual as the borrower, where the loan agreement does not specify a repayment deadline (repayment upon request) and the loan is not secured, it is not allowed to automatically reclassify the loan as a taxable distribution.

The Supreme Court ruled that simply the fact that the legal entity has not yet demanded repayment of the loan and that the statute of limitations for the claim has not yet expired is not sufficient for the tax authority to treat the funds received by the individual under the loan agreement as taxable income.

The court explained that for taxation, the decisive factor is the concealed legal transaction, which the tax authority should have determined if it had found, based on evidence or indications, that the loan agreement actually hides another legal transaction, such as debt forgiveness. However, if this cannot be proven, the funds received under the loan agreement should be treated as a loan, which is not subject to income tax.

The ruling represents an important decision regarding the taxation of loans between related parties and highlights the necessity of a thorough review of circumstances and evidence in each particular case in order to identify any potential abuse of the loan instrument for hidden profit distribution.

NEW RECIPROCAL TARIFFS FOR IMPORTING GOODS INTO THE U.S.

As of 5 April 2025, the first general phase of the new so-called reciprocal tariffs, set at additional 10%, has come into effect. These tariffs were introduced by U.S. on the import of goods into the U.S. from most countries and territories around the world, including the EU.

The U.S. has also previously implemented several so-called sectoral tariffs. Among other things, a 25% tariff on the import of steel and aluminum came into effect in mid-March, and on 3 April 2025, an additional 25% tariff on cars was introduced. Similar additional tariffs on car parts are expected to follow in May or later. Reciprocal tariffs do not apply to these goods. They also currently do not apply to pharmaceuticals, copper, chips, wood, gold, energy, and certain minerals that are not available in the U.S.

The EU is planning countermeasures in response to tariffs on steel and aluminum imports into the U.S., specifically through the gradual introduction of 25% additional tariffs on U.S. goods. After President Trump froze additional tariffs increase on 9 April 2025, it was confirmed in Brussels on 10 April 2025 that the introduction of countermeasures against U.S. tariffs on steel and aluminum imports would be postponed for 90 days but will be implemented if negotiations with the U.S. do not yield results.

Additional tariffs on steel and aluminum imports, as well as the 25% additional tariffs on car imports into the U.S., remain in effect. Additionally, during the 90-day freeze, a 10% additional tariff applies to virtually all countries in the world. Currently, the potential introduction of 10-25% tariffs for the pharmaceutical and semiconductor sectors is also expected.

NEW DEVELOPMENTS IN THE FIELD OF CRYPTO-ASSETS AND DERIVATIVES

On 17 April 2025, the Ministry of Finance published draft Act on tax on profit from disposal of crypto-assets and a draft amendment to the Act on tax on profit from disposal of derivatives (ZDDOIFI). According to proposals (if adopted in the proposed wording), both profits from the sale of crypto-assets and profits from derivatives will be subject to a 25% tax.

Interested stakeholders can submit their comments on these proposals until 5 May 2025.

2025 EY LAW STUDY

EY has released a new EY Law study that provides insight into key challenges and opportunities for legal departments. The study reveals that most legal departments are currently facing significant challenges due to global shifts – 76 % cite geopolitical developments, 75 %the regulatory environment, and 74 % technological advancements. Although 83 %of legal professionals expect their budgets to increase, 87 % are simultaneously focused on cost reduction. Regulatory compliance remains the top priority, yet 60 % of departments see it as a challenge due to rapidly evolving regulations. Furthermore, 75 % of legal departments are enhancing their approaches to technology and data, with 25 % already using generative AI in various tasks.

The report provides guidance on potential opportunities where legal departments may need to adapt their approach to operational strategy, risk and compliance, technology and data, sourcing, and talent development. Based on insights form over 1,000 General Counsel and Chief Legal Officers, the study aims to help legal teams confidently shape their future.

Read more about the challenges of legal services – How legal departments can innovate with confidence | EY - Global.