Tax News - July 2026

I. EU ANNOUNCES A COMPREHENSIVE TAX SIMPLIFICATION PACKAGE

On 24 June 2026, the European Commission presented a tax simplification package aimed at reducing administrative burdens for businesses and simplifying the application of direct tax rules within the EU. The proposed changes include a tax “omnibus”, covering withholding taxes, anti-tax avoidance rules (ATAD), cross-border reorganisations and mechanisms for resolving tax disputes between Member States. The Commission estimates that the proposed measures could generate significant compliance cost savings for businesses and increase legal certainty in cross-border operations.

An important part of the package is also the recast of the Directive on Administrative Cooperation (DAC), through which the Commission seeks to harmonise and simplify the existing reporting and information exchange rules applicable to tax authorities. The objective of the proposal is to reduce the fragmentation of rules, improve the quality of tax data and simplify compliance obligations for businesses, while maintaining the current level of tax transparency.

You can read more about the proposed changes, the expected timeline and the potential impact on businesses in our article “EU Tax Simplification Package Unveiled: What Businesses Need to Know”.

II. DEADLINE FOR FILING AN ANNUAL PERSONAL INCOME TAX RETURN: 31 JULY 2026

Taxpayers who did not receive their informative personal income tax assessment for the 2025 tax year must file an annual personal income tax return themselves. The filing deadline is 31 July 2026. This obligation applies regardless of the amount of income received, provided that the individual earned income subject to personal income tax during 2025.

FURS prepares informative income tax assessments based on information available from official records and data submitted by income payers. In practice, the obligation to file a tax return independently most commonly affects individuals who received certain types of foreign-source income or other income that was not available to the tax authorities when the informative assessments were prepared.

Taxpayers are therefore advised to verify whether an informative income tax assessment was issued to them and, if not, to ensure that the tax return is submitted on time through the eDavki portal or by another prescribed filing method.

III. UPDATED LIST OF HIGH-RISK COUNTRIES

The Office for Money Laundering Prevention of the Republic of Slovenia has published an updated list of countries posing a high or increased risk of money laundering or terrorist financing.

Among the updates, Bosnia and Herzegovina and Iraq have been newly added to the list of jurisdictions under increased monitoring maintained by the Financial Action Task Force (FATF). At the same time, Algeria and Namibia have been removed from the FATF list.

Despite their removal from the FATF list, Algeria and Namibia remain included on the consolidated list of high-risk countries used by entities subject to anti-money laundering and counter-terrorist financing obligations. The reason for their continued inclusion is that both countries remain listed as high-risk third countries under the relevant delegated regulation of the European Union.

Doing business with entities from high-risk jurisdictions requires enhanced due diligence measures, including additional verification of the business partner, the source of funds and the purpose of transactions, as well as increased monitoring of the business relationship. Certain transactions must also be reported to the Office for Money Laundering Prevention of the Republic of Slovenia.

IV. CJEU: YEAR-END TRANSFER PRICING ADJUSTMENTS ARE NOT AUTOMATICALLY SUBJECT TO VAT

On 13 May 2026, the Court of Justice of the European Union (CJEU), in the case Stellantis Portugal (C-603/24), provided important clarification regarding the VAT treatment of transfer pricing adjustments made by entities within multinational groups at year-end. The judgment confirms that such adjustments cannot automatically be regarded as consideration for services subject to VAT.

The case concerned the Portuguese vehicle distributor Stellantis Portugal (formerly General Motors Portugal), which purchased vehicles from related manufacturers within the group and sold them on the Portuguese market. In accordance with intra-group agreements, transfer prices were adjusted at year-end to ensure a predetermined level of profitability for the distributor. The adjustments were implemented through credit notes or debit notes and were calculated based on the distributor’s overall cost base.

The Portuguese tax authorities took the view that the payments in question effectively constituted consideration for repair services provided by the distributor in connection with the vehicles and therefore required the application of VAT.

The CJEU disagreed with this interpretation and emphasised that the mere existence of a payment is not sufficient for a transaction to be subject to VAT. For an obligation to account for VAT to arise, two key conditions must be met simultaneously: there must be a legal relationship involving reciprocal obligations between the parties, and there must be a direct link between an identifiable supply of goods or services and the consideration received.

In the case at hand, the Court found that the transfer pricing adjustments were intended to ensure the distributor’s target profit level and did not constitute payment for specific, clearly identifiable services. Based on the above, the CJEU concluded that the transfer pricing adjustments at issue did not constitute consideration for the supply of services and therefore were not subject to VAT on that basis. The Court nevertheless indicated that, in certain circumstances, similar adjustments could potentially be treated as an adjustment to the price of the underlying transaction, although it did not substantively address that issue in this particular case.

The judgment provides important guidance for multinational groups that apply year-end transfer pricing adjustment mechanisms. We recommend that businesses review the contractual basis for such adjustments, the manner in which they are documented and their VAT treatment. Particular attention should be paid to situations where adjustments could be linked to a specific supply of goods or services, or where they may affect the price of the original transaction.