Beneficial owners eligible for tax relief - Slovenian debt securities
The following types of beneficial owners are recognised for tax purposes in Slovenia:
- Residents of Double Taxation Treaty (DTT) countries
- Non-resident legal entities
- EU parent company/subsidiary
- EU/EEA resident entities
Residents of Double Taxation Treaty (DTT) countries
Relief at source and quick refund from withholding tax on interest from Slovenian debt securities are not available through Clearstream Banking.
A standard refund of withholding tax is available through Clearstream Banking to Beneficial owners qualifying for the benefit of a reduced rate of withholding tax in accordance with the Double Taxation Treaty (DTT) between their country of residence and Slovenia.
The customer can reclaim withholding tax on behalf of the beneficial owner through Clearstream Banking by submitting the appropriate documentation.
The maximum rate of withholding tax is defined in the relevant DTT.
Non-resident legal entities
According to Slovenian legislation, Non-residents can benefit from a 15% withholding tax rate on interest from non-listed corporate bonds and 0% on interest from non-listed bank bonds (Statutory tax relief - 70. article, paragraph (1), 2.c of Corpor. Tax Act do not apply on withholding tax on interest payments for bank bonds not listed on organized market and paid to beneficial holder that is legal entity who has their seat or place of effective management or residence in countries other than the EU Member States, where the general and/or average nominal profit tax rate is lower than 12.5% and the country is published on a list of countries).
Relief at source and quick refund from withholding tax on interest from Slovenian debt securities are not available through Clearstream Banking.
A standard refund of withholding tax is available through Clearstream Banking to Legal entities not resident in Slovenia for tax purposes.
EU parent companies and subsidiaries
No withholding tax applies to interest distributed to EU parent companies or subsidiaries under conditions set forth in EU directive 2011/96/EU on condition that the shareholder holds at least 25 % of the capital of the company for a minimum period of 24 months.
Relief at source and quick refund from withholding tax on interest from Slovenian debt securities are not available through Clearstream Banking.
A full standard refund of withholding tax is available through Clearstream Banking to European Union (EU) parent companies and subsidiaries.
EU/EEA resident entities
No withholding tax on interest paid to legal entities, pension funds and investment funds resident of the EU or EEA (excluding the Principality of Liechtenstein), if the recipient of the interest is not able to set off the applicable Slovenian withholding tax in its country of residence.
Relief at source and quick refund from withholding tax on interest from Slovenian debt securities are not available through Clearstream Banking.
A full standard refund of withholding tax is available through Clearstream Banking to EU/EEA resident entities.