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Slovenia's New ATAD-Compliant GAAR and CFC Rules from 2019

22 January 2019

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Approved Changes

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Slovenia

Slovenia has implemented a new general anti-abuse rule (GAAR) and controlled foreign company (CFC) rules in compliance with the EU Anti-Tax Avoidance Directive. The new rules are implemented through amendments to Slovenia's Corporate Tax Act (the Act) GAAR The new GAAR provides that when determining a taxpayer's tax liability, and in particular the recognition of a tax benefit or entitlement under the Act, the tax authority may disregard a non-genuine arrangement or series of arrangements if the main purpose or one of the main purposes was to obtain a benefit not in accordance with the object and purpose of the...