DT17102 - Slovenia: Treaty summary
The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Slovenia are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.
In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details. The text of the treaty can be found on gov.uk .
| Subjects | Comments | Article |
|---|---|---|
| Portfolio dividends | 15% | 10 |
| Dividends on direct investments | 0% | 10 |
| Conditions for lower rate on dividends on direct investments | The beneficial owner is a company which holds directly at least 20% of the capital of the company paying the dividends. | 10 |
| Property income dividends | 15% | 10 |
| Interest | 5% (Note 1) | 11 |
| Royalties | 5% | 12 |
| Government pensions | Taxable only in Slovenia unless the individual is a resident and national of the UK | 18 |
| Other pensions | Taxable only in the UK | 17 |
| Arbitration | Yes (Note 2) | Under MLI |
Note 1: Interest is taxable only in the UK where such interest is paid:
- to the UK Government, a political subdivision or a local authority of the UK Government
- in respect of a loan made, guaranteed or insured, or any other debt-claim or credit guaranteed or insured, by the UK Export Credits Guarantee Department
- in respect of a loan made, guaranteed or insured by The Bank of England
- the payer and the recipient are both companies and either company owns directly at least 20% of the capital of the other company, or a third company, being a resident of a Contracting State, holds directly at least 20% of the capital of both the paying company and the recipient company
Note 2: Arbitration provisions apply under the MLI to cases:
- presented to the competent authority of a Contracting State on or after 1 October 2018; and
- presented to the competent authority of a Contracting State prior to 1 October 2018 only to the extent that the competent authorities of both Contracting States agree that it will apply to that specific case