Executive Summary
Slovenia has released critical updates on Pillar Two implementation, introducing four permanent safe harbours and extending the transitional CbCR safe harbour to FY2027. The government also extended simplified expense rules under the ZIURS intervention law for 2026 and introduced a €2 per-item customs processing fee for non-EU e-commerce parcels effective November 2026. Additional compliance alerts cover anti-dumping measures, company car fringe benefits, corporate risk indicators, and a major illicit tobacco seizure.
Important Updates
Slovenia Updates Pillar Two Top-Up Tax Guidance with OECD Side-by-Side Safe Harbours
On 5 November 2026, the Financial Administration (FURS) released a comprehensive update to its Top-Up Tax guidance, incorporating the OECD’s July 2026 ‘S’ide-by-Side” package of simplified safe harbours. The guidance introduces four new permanent safe harbours: Simplified ETR, Simplified SBIE, Substance-Based Income Exclusion (SbS), and Ultimate Parent Entity (UPE). These allow MNE groups with revenues ≥€750 million to use Country-by-Country Reporting data for simplified calculations, significantly reducing compliance burdens for low-risk profiles. The transitional CbCR safe harbour, originally covering FY2024–2026, has been extended to FY2027.
The update also provides final versions of the GloBE-ODPD (Top-Up Tax Calculation) and GloBE-OPD (Top-Up Tax Return) forms for 2026, revises the GloBE Information Return (GIR) filing process under DAC9, and clarifies investment deduction rules for tangible assets. The GIR must be filed within 15 months of the fiscal year-end (18 months for the first year), with late filing penalties of €250 per day up to €100,000. FURS will host webinars in December 2026 on the new forms.
Sources: FURS Guidance
Slovenia Details Permanent Safe Harbour for Substance-Based Income Exclusion under Pillar Two
On 3 November 2026, FURS published a dedicated technical guide operationalizing the permanent Substance-Based Income Exclusion (SBIE) safe harbour from the OECD Side-by-Side package. The safe harbour permits MNE groups to exclude a fixed 5% return on the carrying value of eligible tangible assets (property, plant, equipment, natural resources, right-of-use assets) and 5% on eligible payroll costs (full-time equivalents) from the GloBE income base, eliminating the need for detailed substance-based carve-out calculations.
The election is made annually via the GloBE Information Return (GIR) and is irrevocable for the chosen fiscal year. Groups must retain supporting documentation for 10 years. This safe harbour is particularly beneficial for asset-intensive sectors such as manufacturing, energy, infrastructure, and real estate, though high-margin groups may find the standard SBIE calculation more advantageous. Incorrect elections may trigger top-up tax reassessments plus 2% monthly interest. The guide applies to fiscal years beginning on or after 31 December 2023 and supersedes previous transitional SBIE guidance.
Sources: FURS Technical Guide
Slovenia Extends Standardized Expense Rules for Tax Base Determination Under Intervention Law ZIURS
On 16 October 2026, FURS clarified the application of the Intervention Measures for the Development of Slovenia Act (ZIURS), which modifies tax base determination using standardized (lump-sum) expenses for sole proprietors, farmers, and micro-enterprises. The provisions apply retroactively from 1 January 2026, affecting the 2026 tax year. For 2026, standardized expense rates are increased for sectors such as hospitality (e.g., catering rate raised to 60% of revenue from 50%), transport, and agriculture to reflect inflation. The revenue eligibility threshold for the cash-basis regime is temporarily raised to €200,000 from €100,000.
Taxpayers opting for the simplified regime forfeit the right to deduct actual expenses, input VAT (if VAT registered), and tax loss carryforwards for the period. The election is optional but binding for the full tax year and must be made by the deadline for the first advance payment of income tax (typically 10 February 2026 for sole proprietors) via the eDavki portal. Final settlement occurs with the annual return due by 31 March 2027. Non-compliance triggers penalty interest at 1.5% per month and potential reassessment based on actual expenses. FURS will publish detailed rate tables by 31 October 2026.
Sources: Government Announcement
Slovenia Introduces EUR 2 Processing Fee per Item for Non-EU Online Parcels
On 15 October 2026, FURS announced a new customs processing fee of €2 per customs line item for goods purchased from non-EU online retailers, effective tentatively from 1 November 2026. This measure implements the EU Customs Reform Package, which abolishes the €150 low-value consignment relief and introduces a simplified declaration for e-commerce shipments up to €150. The fee is separate from import VAT (22% in Slovenia) and any excise duties, and applies per product line within a parcel (e.g., three distinct items incur €6).
Payment is collected by postal operators or couriers (Posta Slovenije, DHL, DPD, GLS) upon delivery or via pre-payment platforms. Non-EU sellers must register for the Import One-Stop Shop (IOSS) via an EU intermediary by 31 October 2026 to collect VAT at point of sale; otherwise, the buyer pays VAT plus the fee at delivery. The measure aims to level the playing field for EU-based retailers. Low-value shipments face a disproportionate cost increase (e.g., a €5 item incurs a 62% surcharge). Penalties for carriers failing to collect range from €500 to €50,000, and goods may be destroyed or returned.
Sources: Government Announcement
Secondary Regulatory & Regional Updates
- Air Passenger Compensation Tax Exemption: FURS guidance confirms lump-sum compensation under EU Regulation 261/2004 (€250–€600) is exempt from personal income tax under Article 19(7) of ZDoh-2, effective immediately and retroactively. Other compensation (expenses, damages) remains taxable. FURS Guidance
- New Anti-Dumping Measure No. 94/2026: FURS added the 94th anti-dumping/countervailing measure of 2026, implementing EU definitive duties on products such as steel, aluminium, ceramics, or chemicals from non-EU countries. Importers must declare correct TARIC codes immediately; duties effective from the underlying EU regulation’s entry into force. FURS Register
- Widespread Errors in Company Car Fringe Benefit Reporting: FURS analysis of REK forms revealed frequent errors: mismatched CO2/engine power vs. benefit rates, incorrect 1.5%/2% monthly rates, failure to adjust for vehicle unavailability, and shared-use vehicle misreporting. Employers must review and correct REK forms for the last five years; targeted audits are announced. FURS Alert
- Risk Indicators Linked to Accounting Profit Published: Commercial companies can now access their risk scores for the ‘accounting profit’ cluster via the eDavki portal. Indicators cover low margins vs. benchmarks, accounting-tax profit discrepancies, unusual loss carryforwards, and volatile effective tax rates. High-risk entities should consider voluntary disclosure to mitigate penalties up to 100% of unpaid tax. Government Announcement
- Major Illicit Cigarette Factory Uncovered Near Lendava: FURS seized at least 14 million cigarettes and 44 tonnes of raw tobacco in one of Europe’s largest illicit factory busts, evading over €10 million in excise and VAT. The case underscores supply chain due diligence obligations under EU Tobacco Traceability System and may trigger targeted audits of tobacco traders in the Pomurje region in Q4 2026. Government Announcement
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.