Tax News, November 2025

In the November edition of our tax news, we inform you about the law introducing a winter bonus and changes to the system of normalized costs for self-entrepreneurs, the new European regulation on instant payments, a notice regarding the timely submission of CbC reports, the law on the exchange of electronic invoices and other electronic documents, and the amendments to the Corporate Income Tax Act.

LAW INTRODUCING WINTER BONUS AND CHANGES TO THE SYSTEM OF NORMALIZED COSTS FOR SELF-ENTREPRENEURS IS ALREADY IN FORCE

On 20 November 2025, the law introducing a winter bonus and changes to the system of normalized costs for self-entrepreneurs entered into force.

The law introduces a winter bonus  in the amount of half the minimum wage, which will be granted to all employees. This year, it amounts to EUR 639 and must be paid no later than 18 December 2025. Companies with identified liquidity problems may pay the remainder of the bonus by 31 March 2026, except for the public sector, where the extended deadline is not permitted. The law also stipulates that the winter allowance is exempt from social security contributions and tax within the existing tax reliefs, introducing a special provision related only to 2025 tax year.

The law also includes changes to the system for standardized costs of self-entrepreneurs, including raising the income thresholds for entry into the full standardized cost system from EUR 60,000 to EUR 120,000, and for part-time standardized costs self-entrepreneurs from EUR 30,000 to EUR 50,000. The conditions for exit and provisions regarding the treatment of the tax base in this system have also been adjusted.

EU REGULATION ON INSTANT PAYMENTS BRINGS SIGNIFICANT CHANGES

As of 9 October 2025, the Regulation on Instant Payments entered into force, introducing significant changes in the execution of payment transactions for users. The purpose of the regulation is to ensure faster, safer, and more efficient operations and to harmonize the availability of instant payments across the euro area.

All banks, savings institutions, and payment service providers within the SEPA (Single Euro Payments Area) will be required to enable domestic and cross-border instant payments in euros through all existing channels, operating continuously, 24 hours a day, every day of the year. Funds will be available to the recipient within seconds, eliminating time constraints and allowing immediate access to money. From now on, instant payments will be mandatory in all euro area countries, while EU member states whose currency is not the euro, must provide this option by 2027. The regulation also stipulates that fees for instant payments must be the same as for standard credit transfers, ensuring fair treatment of users.

In addition to faster payment execution, the regulation introduces additional security mechanisms, such as verifying the match between the recipient’s name and IBAN, which reduces the risk of fraud. It will also allow the setting of daily and individual limits to prevent transactions with unusually high amounts.

With this measure, the European Union strengthens the digital transformation of the financial system, where transactions are fast, secure, and free from time restrictions.

NOTICE REGARDING SUBMISSION OF CBC REPORTS 

The Slovenian Financial Administration (FURS) informs reporting entities that, in accordance with Chapter III.B of Part Four of the Tax Procedure Act (ZDavP-2), they must submit Country-by-Country (CbC) report via the production communication B2B channel no later than 12 months after the last day of the reporting multinational group’s financial year. For a financial year ending on 31 December 2024, the submission deadline is 31 December 2025.

Reporting entities must submit CbC reports in accordance with the delivery instructions in Annex 21 of the Rules on Amendments and Supplements to the Rules on the Implementation of the Tax Procedure Act and in compliance with the Technical Protocol published on the Financial Administration’s website (www.fu.gov.si/cbcr).

Financial Administration will verify received reports and send a status message via the B2B channel. If any irregularities are detected, the report will be rejected, and the reporting entity must resubmit a corrected CbC report.

Reporting entities submitting a CbC report for the first time, or those changing their server certificate, must register their server certificate in the eDavki system (document Edp-PriSP) before starting the reporting process. After successful registration, they must send a notification to sd.fu@gov.si, confirming that the registration was successful and providing the document number or the entity’s tax number. Next, they must install the ZBS_B2BService application (version 2.12), import the FURS B2B profile for the production environment, and ensure that the appropriate intermediate and root certificates (Entrust EV TLS Issuing RSA CA 2 and Sectigo Public Server Authentication Root R46) are properly imported into the trusted store. After this, the reporting entity sends, via the B2B channel, a profile containing the public key of the digital certificate used for file signing; profile registration is automatic. Once these steps are completed, CbC report exchange may begin. A test environment for report submission is not available.

NEW DEVELOPMENTS IN THE FIELD OF ELECTRONIC INVOICE EXCHANGE BROUGHT BY THE ACT ON THE EXCHANGE OF ELECTRONIC INVOICES AND OTHER ELECTRONIC DOCUMENTS

On 1 January 2028, the Act on the Exchange of Electronic Invoices and Other Electronic Documents will come into force in Slovenia. This Act transposes Council Directive (EU) 2025/516/EU from 11 March 2025, amending Directive 2006/112/EC as regards the VAT rules for the digital age into legal order of the Republic of Slovenia. The most notable effects of the new Act are as follows:

Mandatory exchange of electronic invoices between business entities

The Act introduces mandatory electronic invoicing for all business entities entered in the Slovenian Business Register and for natural persons engaged in the supply of goods and services in Slovenia.

This means that from 1 January 2028, the use of e-invoices will be mandatory not only for the public Budget Users and public procurement contractors, but also for all Slovenian companies in the case of business-to-business (B2B) transactions. Paper invoices will still be permitted for business-to-consumer (B2C) transactions and transactions with foreign companies.

Arrangements for consumers

The Act does not introduce any changes for consumers, as companies will continue to issue paper invoices unless consumers agree with companies to issue invoices in electronic form. Consumers will also have the right to withdraw their consent to receive e-invoices.

Possible ways of exchanging e-invoices

An e-invoice is a structured electronic document in XML format, which enables complete automation of business operations. An invoice in PDF format is not recognized as an e-invoice. According to the Law on Mandatory Exchange of Electronic Invoices, visualization of e-invoices is only mandatory for consumers. The Act also stipulates that the exchange of e-invoices will be decentralized and will take place in four ways, namely via:

• E-path providers
• Own systems for direct exchange
• The international PEPPOL network
• The free miniCheckout application for entities with a smaller volume of business

All the above methods of exchange will be conducted via secure electronic channels, therefore sending via email will not be permitted, except when the recipient of the invoice is a natural person consumer.

It is also worth noting that the Act on the Mandatory Exchange of Electronic Invoices and Other Electronic Documents does not provide for reporting exchanged e-invoices to the Financial Administration of the Republic of Slovenia. The method of confirming cash invoices therefore remains unchanged, as the Act does not interfere with the provisions of the Fiscal Verification of Invoices Act. Only the form of the invoice is changing from paper to electronic.

Exchange of e-documents

The adopted Act on the Exchange of Electronic Invoices and Other Electronic Documents does not prescribe the mandatory exchange of e-documents, but it does set standards and methods of exchange if companies decide to use it. Such documents include e-purchase orders, e-delivery notes, e-reminders, and e-IOPs (statements of open items).

AMENDMENTS TO THE CORPORATE INCOME TAX ACT (ZDDPO-2V)

On 15 November 2025, amendments to the Corporate Income Tax Act (ZDDPO -2V) entered into force, as published in the Official Gazette of the Republic of Slovenia, No. 85/2025 on 31 October 2025.

The amendments will apply as of 1 January 2026 and introduce several important changes:

1. New definition of a branch of activity

A branch of activity is defined as assets (all assets and liabilities) attributed to a part of the company which, upon the transfer of assets, represents an independent business unit from an organizational point of view. The condition of completeness must be met at the time of the transaction, not merely in the future.

2. Spin-off as a tax-neutral transaction

A spin-off carried out in accordance with the Companies Act (ZGD-1) is considered a transfer of assets with a neutral tax effect, provided the conditions of the branch of activity definition are met.

3. Demergers and mergers

The amendment to Article 48 explicitly states that tax-neutral treatment applies to demerger by incorporation or by acquisition. In the case of mergers or demergers, the assets must constitute an independent business unit.

4. Investment funds

For funds under the ZOAIS, a 0% tax rate is introduced if, by 30 November of the tax period, they distribute at least 75% of the business profit from the previous period (excluding unrealized gains). Income from leasing activities, financial leasing, and lending is excluded.

5. Editorial correction

The reference to Article 32 (thin capitalization rule) has been deleted from Article 74, as Article 32 has been repealed.