On 15 September 2026, the Slovenian Government disclosed the first quantitative results of the Minimum Tax (Pillar Two) implementation, effective for fiscal years starting on or after 31 December 2023. As of 10 September 2026, multinational enterprise groups and large domestic groups filed returns showing a total top-up tax liability of €8.68 million. This comprises €4.63 million in Domestic Top-up Tax (DTT) and €4.05 million in Undertaxed Profits Rule (UTPR) amounts. The figures confirm the operational effectiveness of Slovenia’s transposition of EU Directive 2022/2523 into the Corporate Income Tax Act (ZDDPO-2). The revenue, while modest relative to total CIT, validates the compliance infrastructure and signals that low-tax jurisdictions in group structures are being neutralized.
Key Takeaways
- Filing Threshold Met: Groups with €750M+ consolidated revenue are complying; the €8.7M reflects initial high-risk jurisdictions.
- DTT vs UTPR Split: Near-equal split suggests both low-tax subsidiaries abroad and foreign parent low-taxation are relevant for Slovenian groups.
- Data Quality: FURS will use this data for risk profiling; groups should ensure GloBE income calculations align with financial accounting standards.
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.
Source: Read Official Announcement