Tax News, May 2026

ACT ON INTERVENTION MEASURES FOR THE DEVELOPMENT OF SLOVENIA ADOPTED

On 11 May 2026, the National Assembly of the Republic of Slovenia adopted the Act on Intervention Measures for the Development of Slovenia (hereinafter: “ZIURS”). The Act lays down measures to mitigate the costs of basic necessities and of certain energy products, and at the same time introduces changes in the areas of the treatment of small businesses and flat-rate taxpayers, taxation and social security contributions, healthcare, and pensions.

The Act introduces changes in the following areas:

• Amendments to the Personal Income Tax Act (ZDoh‑2) – Within the scope of taxation of business income, the Act modifies the system of normalized expenses and introduces a new progressive scale based on the level of income and the taxpayer’s insurance status. Fully insured self-employed persons will be able to remain in the system up to EUR 150,000 in revenue, while others up to EUR 70,000. The tax rate on rental income is reduced from 25% to 15%, and to 5% for long-term rentals to young persons and young families. The amendments should apply to tax years beginning on or after 1 January 2026 (also retroactively).
• Amendments to the Social Security Contributions Act (ZPSV) – A so-called social security cap or maximum base for the calculation and payment of social security contributions is introduced, set at EUR 7,500 per month. The provisions should apply as of 1 July 2026.
• Amendments to the Pension and Disability Insurance Act (ZPIZ-2) – The receipt of a full old-age pension will be allowed even while continuing to work or upon re-employment after retirement. In addition, a new minimum contribution base is introduced for self-employed persons and farmers with low income. The new arrangement should apply as of 1 July 2026.
• Amendments to the Employment Relationships Act (ZDR-1) – An employment contract may henceforth terminate once the employee meets the conditions for an old-age pension, unless the employee timely proposes the continuation of employment. The employee may propose the continuation of the employment relationship without interruption, an amendment to the employment contract, or the conclusion of a new employment contract. For employees who already meet the retirement conditions upon the law’s entry into force or who will meet them by 31 December 2026, a one-year transitional period applies. During this period, they must agree with the employer on continued work; otherwise, their employment relationship will terminate.
• Amendments to the Value Added Tax Act (ZDDV-1) – VAT on basic foodstuffs is reduced to 5%. The measure aims to mitigate living costs and reduce the impact of inflation on households. The changes will apply as of the first day of the second month following the law’s entry into force.
• Healthcare-related amendments – The intervention act amends the Health Care Services Act (ZZDej), the Act on Additional Intervention Measures in the Field of Healthcare (ZDIUPZ), and the Health Care and Health Insurance Act (ZZVZZ). The law changes the framework governing consents for healthcare professionals to perform work and the cooperation between public institutions and private providers of healthcare services. In addition, the ZIURS also affects the regulation of certain rights and obligations arising from health insurance.
• ZIURS also includes amendments relating to the Act on the Right to a Winter Bonus and the Long-Term Care Act.

Temporary measures

• The Act also introduces three temporary intervention measures. In the area of VAT, a reduced 9.5% VAT rate is temporarily introduced for energy products with the aim of mitigating the effects of high energy prices on households and the economy. Furthermore, the ZIURS postpones the application of the new Hospitality Act (ZGos-1) until 2027 and, in the field of healthcare services, introduces limitations on recourse claims by the Health Insurance Institute of Slovenia (ZZZS) against employers in cases of workplace injuries, except in cases of intentional conduct.

The National Assembly, at its extraordinary session on 27 May 2026, decided that a subsequent legislative referendum on the Act on Intervention Measures for the Development of Slovenia is not admissible, as the Act, due to its tax provisions, cannot be subject to referendum decision-making. Consequently, the Act will enter into force on the day following its publication in the Official Gazette of the Republic of Slovenia.

NEW EU RULES TO STRENGTHEN THE FIGHT AGAINST TAX FRAUD

Ministers for economic and financial affairs of the European Union member states have supported new rules aimed at strengthening the fight against cross-border value added tax fraud. The proposed changes will grant the European public prosecutor’s office (EPPO) and the European anti-fraud office (OLAF) more direct access to VAT data at the EU level.

The objective of the new rules is to improve cooperation between national tax authorities and EU institutions, as well as to remove existing obstacles that may slow down investigations of suspected cross-border VAT fraud. While Member States generally support the proposal, they also emphasize the importance of legal certainty, proportionality and the protection of personal data.

Cross-border VAT fraud, particularly so-called carousel fraud, represents a significant risk to the public finances of EU member states and the EU budget. According to estimates by the European commission, such fraud results in annual losses of between EUR 12.5 billion and EUR 32.8 billion, often involving organized crime groups.

The legislative process has not yet been completed. The European parliament is expected to issue its opinion in July 2026, after which the Council of the EU will continue the formal adoption process.

EU: DRAFT NEW MERGER GUIDELINES UNDER PUBLIC CONSULTATION

On 30 April 2026, the European Commission published a draft of the new guidelines on the assessment of mergers (so-called Merger Guidelines), representing the most comprehensive revision of EU merger control rules in the past two decades.

The purpose of the draft is to update the European Commission’s methodological framework for merger assessment and to adapt it to changing market trends and geopolitical developments. The existing merger guidelines from 2004 and 2008 (i.e. Horizontal Merger Guidelines and Non-Horizontal Merger Guidelines) are to be replaced by a single, comprehensive document.

The key technical novelties described by the European Commission in connection with the draft EU Merger Guidelines can be summarised as follows:

• A unified framework for assessing mergers, with further guidance on burden and standard of proof, evidence, counterfactual analysis, and the assessment of merger harms and benefits.
• Explicit recognition of non-price parameters of competition, including innovation, sustainability, resilience, privacy and diversity.
• Broader guidance on market power, including dynamic competitive potential, out-of-market constraints, buyer power, and entry and expansion.
• Expanded treatment of competitive concerns, including head-to-head competition, loss of innovation and investment, entrenchment, foreclosure, coordination, portfolio effects and information exchange.
• Additional guidance on efficiencies, including dynamic efficiencies and benefits linked to innovation, investment, resilience and sustainability.
• Clarification on legitimate interests that may justify Member State intervention under the EU Merger Regulation.

The draft is currently under public consultation, with the deadline for submitting comments set for 26 June 2026. Adoption of the final version of the guidelines is expected following the conclusion of the consultation, and the European Commission plans to continue engaging stakeholders and to complete the revision by the end of 2026.