Tax News, October 2025

In the October edition of our tax news, we inform you about the intensified control by the Tax Administration regarding the accuracy of tax and social security contribution calculations on work-related expense reimbursements, about the two important developments in the field of customs and trade, specifically the decision by the U.S. administration to exclude generic drugs from the scope of pharmaceutical tariffs and about significant upcoming deadlines under the Carbon Border Adjustment Mechanism (CBAM), we also present the main simplifications introduced by the »Omnibus« package, and we inform you further about the implementation of a new entry exit system at the external Schengen border and about the postponement of deadlines for sustainability reporting.

THE FINANCIAL ADMINISTRATION WARNS OF IRREGULARITIES IN WORK-RELATED EXPENSE REIMBURSEMENTS

The Financial Administration will carry out intensified control activities among employers regarding the accuracy of tax and social security contribution calculations on work-related expense reimbursements.

In an analysis of expense reimbursements carried by the Financial Administration it has been found that meal reimbursements by some payers exceed the amounts set by the 
Decree on the tax treatment of reimbursement of costs and other income from employment. This decree defines the amounts and conditions under which reimbursements are not included in the taxable base. This raises suspicion that meal reimbursements related to work may be used to covertly pay out employment income.

Employees who are present at work for at least four hours are entitled to a non-taxable meal reimbursement of up to €7.96 per day. If they are present for ten hours or more, the non-taxable reimbursement increases by €0.99 for each completed hour after eight hours. The same conditions apply to employees receiving employment income from abroad.

Transportation allowance is not included in the taxable base up to €0.21 per kilometre, provided the distance between the residence and the workplace is at least one kilometre. If the total monthly amount is less than €140, a non-taxable reimbursement of that amount may be applied. The shortest road connections are considered, and special rules apply for determining the place of usual residence. If an employee uses a company vehicle for private purposes and the employer provides fuel, the transportation allowance should be included in the taxable base.

Any irregularities in the calculation of taxes and social security contributions on meal reimbursements or other work-related reimbursements can be reviewed by the taxpayers themselves in the submitted reportings and corrected before the inspection begins. The Tax Procedure Act (ZDavP-2) allows taxpayers to submit corrected calculations through voluntary disclosure, in which case the taxpayer (employer) is not liable for an offense.

We recommend you review the approach and policies governing reimbursement of costs to employees. Should you require assistance or advice on this topic our team of tax advisors is happy to assist.

US ADMINISTRATION EXCLUDES GENERICS FROM PHARMA TARIFF SCOPE

After months of internal negotiations and speculation, the US administration has announced that additional duties will not be imposed on the import of generic drugs (such as antibiotics, heart or other commonplace medication) to the United States. The recent statement was released simultaneously with the delay of 100% tariffs on name-brand pharmaceutical products.

Although the decision on omitting generics from the scope of additional tariffs is not yet final, it constitutes a significantly different approach to the original idea of imposing duties on most medicine. Generic drugs make up about 90% of pharmaceutical products sold within the United States and are mostly imported from abroad. This statistic continues to spark debate between experts on whether related tariffs are required to protect US manufacturing interests.

Further announcements on the exact scope and application of pharmaceutical tariffs are expected in the coming weeks.

CBAM: IMPORTANT DEADLINES APPROACHING

We would like to notify you of important deadlines coming up for affected importers in the following weeks.

Companies who imported goods subject to the Carbon Border Adjustment Mechanism (CBAM) between 1 July 2025 and 30 September 2025 must submit their quarterly CBAM reports in the CBAM Transitional Registry. The deadline for submitting the quarterly report is 31 October 2025.

The transitional period is also nearing its end, with only one quarterly reporting period remaining for the fourth quarter of 2025. Starting from 1 January 2026, goods falling under the scope of CBAM can only be imported to the EU by companies holding an “authorized CBAM declarant” status. This status must be requested at the national competent CBAM authority (FURS, Slovenian CBAM portal).

It is important to note that based on the recently implemented “Omnibus” simplification package, CBAM obligations only apply to companies who import at least 50 tons of CBAM goods per year. However, the European Commission recommends that companies importing over 40 tons of products subject to CBAM annually should also apply for the authorized declarant status to ensure compliance coverage for potential CBAM obligations.

This simplification does not apply to importers of hydrogen and electricity. Affected importers must obtain authorized declarant status, regardless of the imported quantity.

As a general rule, this status must be acquired prior to importing CBAM goods above the 50 ton de minimis threshold. Due to the large number of expected requests and the limited capacity of competent authorities, companies who submit their application before 31 December 2025 may continue importing CBAM goods from 1 January 2026, regardless of the imported amount.

The conditions to apply for the CBAM authorized declarant status significantly overlap with the criteria to become an Authorized Economic Operator (AEO). Therefore, we note that companies aiming to become authorized declarants may also consider an AEO application simultaneously.

IMPLEMENTATION OF A NEW ENTRY EXIT SYSTEM AT THE EXTERNAL SCHENGEN BORDER

Slovenia, in accordance with EU regulations 2017/2226 and 2025/1534, began implementing the Entry/Exit System (EES) at its external Schengen borders on 12 October 2025, along with other EU member states. The gradual rollout of the system will continue until April 2026. Its purpose is to increase the efficiency of border crossings, enhance the security of countries and control over travelers, and facilitate travel to Europe. Most of the EU member states are participating in the system, except Cyprus, Ireland, Iceland, and Liechtenstein. Additionally, Switzerland and Norway are also not included.

In Slovenia, which does not have a land external Schengen border, the system has been established at border crossings at three airports – Ljubljana Brnik, Maribor Slivnica, and Portorož – as well as at two international maritime border crossings in Koper and Piran.

The system eliminates the time-consuming stamping of passports upon entry and exits from the Schengen area, replacing it with a digital and fully automated verification system. Border control will be upgraded with electronic registration of entries, exits, and refusals of entry for third-country nationals. Biometric identifiers of travelers crossing the external Schengen border will also be checked. This will improve the efficiency of border controls in combating cross-border and organized crime, terrorism, identity fraud, and illegal residence across the entire European Union.

POSTPONEMENT OF DEADLINES FOR SUSTAINABILITY REPORTING

On 25 September 2025, the National Assembly of Slovenia unanimously adopted an amendment to the Companies Act, postponing sustainability reporting deadlines by two years. The amendment, which entered into force on 4 October 2025, aligns with an EU directive designed to ease the burden on companies facing increasingly challenging economic conditions.

Under the new timeline, large companies will begin reporting for the 2027 financial year instead of 2025. Public interest entities with more than 500 employees remain obligated to report for financial year 2024.

Medium-sized and smaller listed companies, excluding micro-enterprises, will now be required to report starting in 2028 instead of 2026.