Tax News - March 2026

I.      CORPORATE INCOME TAX AND TAX ON INCOME FROM BUSINESS ACTIVITIES

Deadline for Filing the Corporate Income Tax Return (CIT Return)

Corporate income taxpayers are approaching one of the most important annual deadlines in the tax calendar. For taxpayers whose tax period corresponds to the calendar year, the deadline for filing the Corporate Income Tax (CIT) return for 2025 is 31 March 2026. The return must be submitted electronically via the eDavki portal.

Different Deadline for Additional Tax Payments after Filing CIT and Tax on Income from Business Activities Returns

The deadline for paying additional tax liabilities after filing the tax returns is set at 30 April, regardless of the date on which the Corporate Income Tax (CIT) return or the Tax on Income from Business Activities return was submitted. Under the new rules, the additional payment is therefore no longer tied to the date of submission of the tax return but to the statutory filing deadline (31 March).

The Financial Administration of the Republic of Slovenia will continue to process refunds arising from filed returns in the same manner as before—as a rule within 30 days from the date of submission of the tax return.

II.    MINIMUM TAX

FARS Announces a New Obligation under the Minimum Tax Act

The Financial Administration of the Republic of Slovenia issued a notice on 6 February 2026 regarding the commencement of obligations under the Minimum Tax Act (ZMD). The minimum tax forms part of the global reform of taxation for large multinational and domestic groups and is based on the OECD GLOBE rules and EU Directive 2022/2523 on a global minimum level of taxation. It represents a completely new, separate taxation system that does not follow Corporate Income Tax (CIT) rules but instead applies specific global standards.

A constituent entity is considered a taxpayer under the Minimum Tax Act (ZMD) if it meets both of the following criteria:

• it is located in Slovenia, and
• it is part of a large multinational group or a large domestic group whose annual consolidated revenue amounts to at least EUR 750 million in at least two of the four financial years preceding the tested year.

This rule follows the international Pillar II standard, which targets the largest multinational groups. According to estimates by the Ministry of Finance, several hundred entities in Slovenia are expected to meet this criterion, meaning the scope of affected taxpayers will be significantly broader than initially anticipated.

The ZMD introduces a global minimum taxation of group profits, which must amount to at least 15 percent at the level of the jurisdiction in which the group operates. This prevents profit shifting into low‑tax jurisdictions, which is one of the core global policy goals of the reform.

The minimum tax consists of two components:

• the top‑up tax, and
• the qualified domestic minimum top‑up tax (QDMTT), which takes precedence and ensures that Slovenia retains the tax base relating to entities operating in Slovenia.

Obligation to submit the domestic top‑up tax return

• the taxpayer must file the return even if no payment obligation arises,
• deadline: 30 June 2026 for financial years ending on or before 31 December 2024,
• the form will be available in the eDavki portal in May 2026.

It is also possible to designate a filing entity that submits a single consolidated return on behalf of all Slovenian constituent entities. However, all entities remain jointly and severally liable for the payment. If a taxpayer does not submit the form themselves, they must indicate which group entity will submit it (either a local or a foreign filing entity).

III.  VALUE ADDED TAX (VAT)

FARS Introduces Stricter Measures for Missing VAT Records

The Financial Administration of the Republic of Slovenia has announced stricter supervision and monthly penalties for taxpayers who fail to submit the mandatory VAT charged records and VAT deduction records. Tax authorities also announce more consistent monitoring of business partners within the supply chain and a more in‑depth review of discrepancies between submitted records and the VAT‑O return.

This development marks the formal end of the adjustment period for taxpayers’ information systems. Taxpayers who fail to submit the required records will now be subject to misdemeanour proceedings.

Prescribed fines:

• legal entities: €4,000–€125,000,
• sole proprietors: €3,000–€50,000,
• individuals: €400–€5,000.

The records must be submitted via the eDavki portal, where taxpayers can also verify whether the individual records have been correctly submitted and aligned with the VAT‑O return.

New Judgment of the EU General Court (T‑646/24): Triangular Simplification May Also Be Applied in a Four‑Party Supply Chain

The General Court of the European Union, in the case MS Kljúčarovci, d.o.o., in liquidation (T‑646/24), issued an important judgment that expands the understanding of the application of the triangular simplification for intra‑EU supplies of goods. The judgment confirms that the simplification may also be applied in a more complex four‑party supply chain (A → B → C → D), including situations where the goods are not physically delivered to the formal purchaser (C) but directly to that purchaser’s customer (D).

This decision represents a significant development in the treatment of chain transactions and provides greater legal clarity for businesses operating within multi‑jurisdictional supply chains.

Essence of the Judgment

The Court held that it is not required for the goods to be physically received by participant C in order for the conditions for the simplification to be met. It is sufficient that the goods are delivered to C’s customer (D), provided that both C and D are identified for VAT purposes in the same Member State.

The Court emphasised that the legal supply is distinct from the physical delivery. The key criterion is the transfer of the right to dispose of the goods as owner, not the physical location where the goods are delivered. A single physical movement of goods may therefore constitute two consecutive legal supplies for VAT purposes.

When the Simplification Can Be Applied in a Four‑Party Chain

The triangular simplification may also be applied in a chain A → B → C → D if the following conditions are fulfilled:

• B acts as an intermediary and is not VAT‑registered in the Member State of C or D,
• the goods move in one single shipment from A to D,
• C and D are identified for VAT purposes in the same Member State,
• the transfer of the right to dispose of the goods is properly documented,
• there are no indicators or evidence of VAT fraud.

The judgment confirms that the involvement of a “customer’s customer” (D) does not prevent the use of the simplification, provided the supply chain is economically and documentarily consistent.

Limitations Related to tax Fraud

Despite the broader applicability of the simplification, the Court underlined an important anti‑fraud safeguard: the simplification cannot be used where a participant in the chain knew, or should have known, that the transactions formed part of tax fraud.

In such cases, the Member State of the intermediary (B) may deny the application of the simplification and impose an obligation to account for VAT, including a sanction‑based VAT liability, especially where the intermediary’s VAT identification number was used within a fraudulent scheme.

IV. CUSTOMS AND IMPORT TAXES

Important Change Regarding the Import of Small Consignments from Non‑EU Countries

The Council of the European Union confirmed in December 2025 an important change that will affect all consumers and online retailers who order or ship goods from third countries. This measure forms part of a broader reform of the EU customs system and addresses the rapidly growing volume of low‑value consignments, particularly from e‑commerce platforms.

At present, consignments valued up to EUR 150 are exempt from customs duties upon import, with only VAT being charged. This means that most small parcels from non‑EU countries enter the EU without additional customs charges.

New rules applicable from 1 July 2026

From 1 July 2026, the EU will introduce a flat customs duty of EUR 3 for low‑value consignments (valued under EUR 150). The flat amount of EUR 3 will be applied to each tariff category of goods in the parcel, often resulting in a charge per individual item.

The measure is temporary and will remain in place until the full customs reform enters into force, which will abolish the EUR 150 threshold and introduce standard customs duty rates for all imported goods. The duty will apply primarily to consignments where the seller is registered in the Import One‑Stop Shop (IOSS) system, which currently covers approximately 93% of all e‑commerce flows entering the EU. Some Member States (e.g. Belgium, France, the Netherlands, Romania) will introduce additional national handling fees as early as 2026, separate from this customs duty.

Purpose of the measure

• Eliminating unfair competitive advantages enjoyed by non‑EU sellers, who often sell goods more cheaply due to the customs duty exemption.
• Reducing the widespread undervaluation of parcels used to avoid paying VAT and customs duties.
• Improving consumer safety, as a large share of goods imported from third countries do not meet EU standards (e.g. toys, electronics).
• Relieving pressure on customs authorities, which handle millions of parcels daily (in 2024 more than 12 million per day).