Tax News, February 2026

THE NATIONAL ASSEMBLY HAS ADOPTED THE NEW EMPLOYEE PROFIT PARTICIPATION ACT

On 11 February 2026, the National Assembly adopted new Employee Profit Participation Act (ZUDDob‑1), which regulates employees’ participation in a company’s profit, the types of profit‑sharing schemes, the related procedure and the special tax treatment.

Novelties introduced by the new Act:

1. Higher thresholds for profit distribution

The new Act increases the share of profits that may be distributed to employees from the current 20% to 33% of the profit of an individual financial year. The upper limit for payments is also raised—from the existing 10% to 20% of the annual gross salary amount.

2. Reward schemes

The Act defines three types of profit‑sharing schemes: a cash scheme with profit distribution in cash, a stock‑based scheme with profit distribution in stocks, and a share-based scheme with profit distribution in shares.

3. Tax treatment of employee income

For the cash scheme, the income—once the conditions are met is taxed at a 30% personal income tax rate as a final tax and is not included in the annual tax base. For the stock‑based or share-based schemes, the income is taxed at a 25% rate as a final tax and is likewise not included in the annual tax base.

4. Corporate income tax relief

The new Act allows companies to claim a 100% tax relief for profits distributed to employees, and this relief can already be used in the following year. Under the previous regime, the relief was subject to a time delay: in the first year, the tax base could be reduced by 70%, and the full 100% reduction was possible only after three years.

5. Registration of agreements no longer required

Under the new Act, registering the profit‑sharing agreement with the Ministry of the Economy, Tourism and Sport in order to claim the tax relief will no longer be necessary.

6. Transitional period

Companies that registered profit‑sharing agreements under the previous Employee Profit Participation Act may continue to use these agreements for profit‑sharing for the financial year beginning up to and including 31 December 2026.

Participation in profit remains voluntary for both the company and the employees. All employees must be included in the profit under the same conditions and criteria, which the company and employees agree upon in a mutual contract.

FURS CRITERIA FOR DETERMINING PRIORITY TAX INSPECTIONS IN 2026

The Financial Administration of the Republic of Slovenia (FURS) has published this year’s criteria for determining priority tax inspections, which are based on risk assessments and applicable tax legislation. In 2026, inspections will focus on areas where risk analysis indicates the highest likelihood of irregularities and potential shortfalls in public revenue.

In the field of value added tax (VAT), the emphasis will be on detecting systemic fraud, especially so called missing trader intra community (MTIC) fraud schemes, in which taxpayers participate in transaction chains with the aim of unlawfully claiming input VAT deductions. FURS will also devote particular attention to taxpayers who claim VAT deductions based on fictitious invoices or private use, as well as those with improper VAT identification. A strong focus will be placed on identifying discrepancies between VAT returns and data from fiscally validated invoices, as such inconsistencies often point to serious irregularities.

In the area of corporate income tax and income from business activities, inspections will target taxpayers suspected of under declaring their tax base, including through inappropriate cost inclusion or failure to file required tax returns. Transfer pricing remains a key focus area, particularly for multinational groups where risk analysis identifies irregularities in the pricing of services, financial transactions, intangible assets, or business reorganizations.

Regarding taxation of individuals, FURS will continue inspecting employers with a high risk of non-compliance. The focus will be on the correct tax treatment of benefits, work related reimbursements, and identifying taxpayers who fail to submit tax and social contribution filings. As part of efforts to combat the grey economy, inspections will also cover activities conducted via online platforms and social networks, where underreporting of income is frequently detected. Controls over fiscal cash registers will be strengthened, as discrepancies between validated receipts and submitted returns often reveal undeclared cash transactions.

FURS will also continue conducting inspections in customs, with a particular emphasis on identifying avoidance of anti-dumping and countervailing duties, verifying the accuracy of customs values, and identifying potential abuses within Customs Procedure 42. In the area of excise duties, inspections will focus on the correct calculation of excise duties for alcohol, beer, energy products, and tobacco, as well as preventing illegal production or movement of tobacco and energy products. Environmental taxes remain an important component of supervisory activities, especially regarding the correct calculation of taxes on wastewater and CO₂ emissions.

A significant part of the inspection framework also consists of activities related to the international exchange of information and reporting on financial accounts, including FATCA obligations and supervision of reporting by digital platform operators.

In 2026, FURS will continue to cooperate closely with other inspection bodies and institutions, particularly in the areas of foreign worker employment, cash-based business operations, gambling, online sales oversight, and food safety controls, where coordinated action among several competent authorities is essential for effective supervision.

FURS ISSUES NOTIFICATION ON NEW MINIMUM TAX OBLIGATION

Financial Administration of the Republic of Slovenia (FURS) has sent a notice in January 2026 to taxpayers regarding potential obligations under the Minimal Tax Act (MTA). Based on available data, including Country‑by‑Country Reports, CbCR notifications and publicly disclosed revenue information, FURS identified entities that may fall under the new minimum tax rules for the 2024 reporting year.

Taxpayer for minimal tax in Slovenia is a constituent entity that meets the following criteria:

• a constituent entity located in Slovenia, and
• part of a multinational enterprise (MNE) group or a large domestic group with annual consolidated revenue of at least EUR 750 million in at least two of the four fiscal years preceding the testing year.

All companies that meet the above-mentioned conditions will have the following reporting obligations in Slovenia:

1. Qualified Domestic Top-Up Tax Return (QDMTT return): the deadline for submission for 2024 is 18 months after end of financial year

Regardless of whether any domestic top‑up tax is due, all identified entities should submit a domestic top‑up tax return through eTax portal within 18 months after the end of 2024 financial year. The first reporting period for qualified domestic top-up tax refers to periods starting on 31 December 2023. The return can be filed centrally by a designated reporting entity, though all Slovenian entities remain jointly liable for the payment of the full domestic top-up tax obligation.

2. GloBE Information Return (GIR) or GIR notification

In case GloBE Information return or GIR will not be submitted in Slovenia, but in another jurisdiction, the Slovenian entity should submit the so-called GIR notification. GIR notification will need to indicate which constituent entity will be responsible for submission of GIR and the jurisdiction of submission.

3. Top-Up tax return

A full top‑up tax return should be submitted only if the actual top‑up tax liability arises, whether under the provisions of MTA, Income Inclusion Rule (IIR) or Undertaxed Profits Rule (UTPR).

CHANGED VAT RETURN PERIOD (DDV‑O)

The Financial Administration of the Republic of Slovenia has carried out a central update of tax periods, assigning taxpayers an appropriate reporting period based on their taxable turnover in 2025. The changes are based on Article 89 of the VAT Act (ZDDV‑1) and Article 156 of the Rules on the Implementation of ZDDV‑1.

After the update, taxpayers have already been allocated either monthly or quarterly reporting, depending on the statutory conditions.

What has changed and what should you pay attention to?

The reporting period can change:

• from quarterly to monthly, when the taxpayer’s turnover in the previous year exceeds the threshold allowed for quarterly reporting,
• from monthly to quarterly, when the taxpayer no longer meets the conditions for monthly reporting.

The eDavki system now uses the newly assigned reporting period when submitting VAT returns.

What are the thresholds for entering each reporting period?

A taxpayer must report monthly if their taxable turnover in the previous calendar year:

• exceeded EUR 210,000 (the most common reason for moving to monthly reporting), or
• if they perform specific types of transactions (e.g., intra‑EU transactions) for which the law requires monthly reporting.

A taxpayer may report quarterly if:

• their taxable turnover in the previous year did not exceed EUR 210,000, and
• they do not perform transactions that would require mandatory monthly reporting.

The threshold of EUR 210,000 is therefore the key criterion determining whether reporting remains quarterly or whether the taxpayer must switch to the monthly regime.

Submission of forms is functioning normally again

Following the completed system update, the submission of DDV‑O, VIES‑KP, PD‑O forms and VAT deduction records is once again fully enabled without restrictions.

EU IMPLEMENTS A CUSTOMS DUTY ON LOW VALUE E-COMMERCE IMPORTS

The EU has agreed to introduce a EUR 3 customs duty on e‑commerce parcels worth less than EUR 150. This new charge will start in July 2026 and is meant to reduce the competitive advantage that non‑EU online sellers currently have over EU businesses. It will serve as a temporary measure until the new EU Customs Data Hub is launched in 2028.

The duty will apply to goods sent directly from non‑EU countries to EU consumers. The Commission and Member States are now preparing the legal and IT systems needed to make the new system work smoothly. A separate handling fee, intended to help customs authorities cover rising processing costs, is currently being negotiated and could begin in November 2026.

These changes are part of a wider plan to modernize EU customs rules. The goal is to better protect EU retailers and consumers as online shopping continues to grow, and to ensure fair competition in the Single Market.

SUBMISSION OF TAX RETURNS BY 2 MARCH 2026

Individuals are required to submit tax returns for income types that were not reported during the year by withholding agents. This mainly concerns rental income, income from capital (interest, dividends, and capital gains from the disposal of securities and ownership interests), as well as gains from derivative financial instruments for the year 2025 by 2 March 2026. This applies to both residents and non-residents of the Republic of Slovenia. The actual filing deadline is 2 March 2026, as the statutory deadline of 28 February falls on a Saturday.

Residents are not required to file a tax return for interest on bank deposits if the total amount in 2025 does not exceed EUR 1,000. Regarding rental income, residents must report all earnings, regardless of the country of origin, while non-residents are only required to report rental income sourced from Slovenia.

Tax returns may be submitted via the eDavki portal, by post, or in person at any financial office in Slovenia. An important change in reporting is that if more than 5 interest or dividend payments were received in 2025, the tax return must be filed electronically via the eDavki portal. In addition, a tax resident is required to submit the return via the eDavki portal if more than 10 transactions related to the sale of securities or investment coupons were carried out in 2025.

INCREASE OF MINIMUM HOURLY RATES AND OTHER PAYMENTS FOLLOWING THE RISE OF THE MINIMUM WAGE

In accordance with the Minimum Wage Act (ZMinP), the Ministry of Labour, Family, Social Affairs and Equal Opportunities (MDDSZ) published in the Official Gazette of the Republic of Slovenia 001/2025 the new minimum wage amount for 2026, which is set at EUR 1,481.88 gross. The adjustment is based on the newly calculated minimum living costs of EUR 791.07 and a 2.7% increase in prices.

This increase impacts several legally regulated amounts, including the following:

• The minimum hourly rate for student or pupil work amounts to EUR 8.98 per hour as of 5 February 2026.
• For occasional work performed by pensioners, the minimum hourly rate from 1 March 2026 to 28 February 2027 is EUR 8.52 per hour, and the annual limit for 2026 is EUR 17,782.56.

In general, the increase in the minimum wage raises all amounts linked to it, including hourly rates, allowances, and tariffs.