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Slovenia Amends Corporate Income Tax Act in Relation to Permanent Establishments, Capital Gains, and Interest Deduction Restrictions

16 February 2024

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Approved Changes

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Slovenia

Slovenia published the Act on Amendments to the Corporate Income Tax Act (ZDDPO-2T) in the Official Gazette on 9 February 2024. The measures of the Act include: New rules to limit the avoidance of permanent establishment (PE) status through commissionaire arrangements and similar strategies; A reduction in the activity period for a construction PE to be considered constituted from 12 months to 6 months; New rules to limit the avoidance of PE status through splitting-up of activities to take advantage of exceptions for activities of a preparatory or ancillary nature; The introduction of a 365-day rule for gains from the...