Costs that occur prior to the entry of a legal entity into the court register may not be treated as tax-deductible, the same as for expenses that are not directly necessary for performing business activities or are not incurred as a consequence of business activity. In general, business expenses that are necessary to generate taxable revenues are fully tax-deductible.
Companies may deduct interest expense on loans from their owners or other associated parties up to a maximum of the amount calculated by using the prescribed interest rate published by the Ministry of Finance.
Certain provisions are only 50% tax-deductible when accrued, with the remaining 50% being treated as tax-deductible when the provision is utilised, as the provisions for warranties granted when selling products or providing services, reorganisations/redundancies, anticipated losses from onerous contracts, pensions, long-service bonuses, and severance payments on retirement. As from 1 January 2022 to 31 December 2026, provisions for pensions, for jubilee awards and for severance pay upon retirement shall be tax deductible 100% when formed for each individual tax period.
Entertainment costs are only 60% tax-deductible, those relating to the supervisory board are 50% tax-deductible.The R&D incentive allows for a 100% deduction of the amount invested in internal R&D activities and the purchase of R&D services. The investment incentive allows for a 40% deduction of the amount invested in certain prescribed equipment and intangible assets, excluding investments in real estate property. Additionally, a special incentive was introduced as part of the post-COVID-19 recovery plan, which allows for a 40% deduction of investment into AI technology, cloud computing, green technology, etc. However, the combined deduction can be used up to the maximum of 63% of the actual tax base.
Bad debt provisions are only tax-deductible if the amount does not exceed the lower of: (i) the arithmetic mean of the bad debts written-off in the past three tax periods, under certain conditions specified in the tax law, and (ii) 1% of taxable revenues of the tax period.
Under certain conditions, a tax-deductible allowance for voluntary supplementary pension insurance may apply (of up to 24% of compulsory contributions for pension and disability insurance for insured employees, capped at EUR 2,819.01/year/employee).
Charitable donations made for humanitarian, disabled, charitable, scientific, educational, medical, sports, cultural, ecological, and religious purposes to residents of Slovenia or of EU or EEA member states are deductible, up to 0.3% of the taxable revenues, plus an additional allowance of 0.2% of the taxable revenues for payments made for cultural purposes and to voluntary organisations that work for the public interest to protect the public from natural and other disasters. As from 1 January 2022, another tax allowance for sport purposes of 3.8% shall be recognised for payments or equivalents to providers of the top sport program for investing in such sport.
Tax losses may be carried forward to subsequent years without a limitation (but only up to a maximum of 63% of the actual tax base), whereas loss carrybacks are not permitted.