The Government of the Republic of Slovenia recently submitted to the Parliament an amendment to the Corporate Income Tax Act (ZDDPO-2). The Amendment to the ZDDPO-2 partly incorporates Council Directive 2016/1164 into the Slovene tax legislature and enshrines the General-Anti-Avoidance-Rule (GAAR), aimed at safeguarding against corporate income tax avoidance and preventing schemes that result in obtaining unlawful tax advantages. The amendment also enshrines the term controlled companies, i.e. a foreign company in which the taxpayer has a shareholding of more than 50% and in which the profits actually paid are less than half of the DDPO that would have been charged to the company under the provisions of the ZDDPO-2. It is expected that the amended ZDDPO-2 shall come into force on January 1st, 2019.
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