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Transcript of Tax News - June - EYFIL… · compliance requirements. ... predicting assignments, the Act received...
In this edition of EY Tax News, we inform you about the implementation of CbCR,
amendments to the taxation of travel expenses for assigned workers and requests for
a tax opinion in cross-border transactions. Further we inform you about expected
changes in the legislation, additional guidance on R&D relief and signed Multilateral
Convention. In addition, we indicate important dates in July 2017.
Implementation of Country-by-Country-Reporting
On 16 June 2017 the Rules for amendments to the Rules for implementation of the
Tax Procedure Act were published in the Official Gazette of Republic of Slovenia
(Off.G. No. 30/2017; the Rules). Based on the Rules some amendments are
implemented with respect to Appendix 20 that relates to reporting about financial
accounts, while new Appendix 18 that related to FATCA reporting is a part of the
Rules and replaces the previous version.
The Rules are valid from 1 July 2017.
In terms of the content, the most important part of the Rules relates to
implementation of guidance for Country-by-Country-Reporting (CbCR). The Rules
mainly follow the Proposal of the Rules which was published by the Slovenian Ministry
of Finance on 19 April 2017.
To emphasize the most important provisions, in the Rules the following CbCR
requirements are defined:
► sources of data that may be used for preparing a CbCR;
► principle of consistency for using the same sources of data over the years
otherwise any change must be disclosed;
30 June 2017
Tax News - June
EY SloveniaTax News
Tax News June 20172
► data on branches (permanent establishments) should be
included under tax jurisdiction where the branch is located
and not under tax jurisdiction where the head office legal
entity is resident;
► an Annex 21 that is a part of the Rules provides an overview
of all items that are included in CbCR, which should be
submitted by a reporting entity in an electronic form;
► CbCR notification should be submitted alongside the CIT
return for the relevant fiscal year through online eTax
system.
The CbCR notification requirement was expanded comparing to the
proposal published in April and should besides definition of a taxpayer
and a reporting entity include also information about their roles within
a multinational group and a definition of a parent company and a group
of companies. The notification form itself is not published yet; however
it is expected that it will be published on the Tax Authorities’ webpage,
presumably in July 2017.
EY Slovenia can help members of multinational group of entities with
clarifying their CbCR obligations and with properly addressing any
compliance requirements.
Taxation of travel expenses for assigned workers
On 17 February 2017 Slovenian Parliament accepted a Transnational Provision of Services Act which entered into
force in March 2017 and will be in use from 1 January 2018. As the Act is limiting business trips and instead
predicting assignments, the Act received many critics. Based on the current legislation in use, reimbursement of travel
expenses incurred while on business trip, such as meal, transportation and lodging are exempt from taxation. While as
such reimbursements are considered as taxable income if on assignment. This means that as of 1 January 2018
employees who will qualify for assignment instead of business trip will be put in a worse position than prior to this date.
Ministry of labour, family, social affairs and equal opportunities unofficially informed us that they have agreed to
amend Article 130 of Employment Relationship Act in a way that will equal the treatment of reimbursement of travel
expenses while on short term assignment with business trips. Presumably the amendment will be adopted in autumn
2017.
Requests for tax opinions on VAT in cross-border transactions
In June 2017 the Financial Authority of Slovenia published the article regarding the test relating to private requests
for a tax opinion in cross-border transactions, to remind the taxpayers on their possibility to file a request relating the
VAT treatment of its cross-border transactions in relevant countries.
As of 1 June 2013 several EU Member States have decided to participate in a test relating to private requests for a tax
opinion regarding the VAT treatment of cross-border transactions. The following countries have agreed to participate
in the project: Belgium, Denmark, Ireland, Estonia, Spain, France, Italy, Cyprus, Latvia, Lithuania, Malta, Hungary,
Portuguese, Finland, Sweden, United Kingdom and Slovenia.
The test is expected to last until 30 September 2018 and European Commission is regularly issuing VAT Cross Border
Rulings which shall help the taxpayers in predicting the tax treatment of its cross-border transactions in different
Member States.
EY Slovenia may help the taxpayers with filing the request for a tax opinion in cross-border transactions to the
Slovenian Tax Authorities or obtain the published opinions which correspond to their transactions.
Tax trends
Ministry of Finance started with the preparation of changes in the tax area. It is planned that the following changes will
be introduced in the future:
► restructuring of tax burdens with amending the ZDoh-2, ZDDPO-2 and extension of the scheme which is
regulating the tonnage tax;
► improving the efficiency of collecting taxes and reducing administrative burdens
► the amendment of ZDavPR and use of pre-numbered receipt book also after the transitional period is over;
► reduction of costs associated with paying taxes in order to improve the business environment (e.g. the use of
online payments or the UJP e-payments for taxpayers who are included in the eTax system).
R&D guidance planned
In addition to already published four tax opinions relating to the research and development (“R&D”) relief the
Slovenian Financial Administration is planning to prepare the guidance on the application of the R&D relief towards
easier applicability of this relief.
OECD Convention signed
On 7 June 2017 the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS (the MLI) was
sign by over 70 Ministers and other high-level representatives. The new convention has been developed under Action
15 of the BEPS project which analysed the possibility of developing a multilateral instrument in order to allow
countries to swiftly amend their tax treaties to implement the tax treaty-related BEPS recommendations and avoid
changes having to be implemented on a treaty-by-treaty basis. It is expected that 1,100 tax treaties will be modified as
a result of signing the MLI. With respect to a specific bilateral tax treaty, the measures will only enter into effect after
both parties to the treaty have deposited its instrument of ratification, acceptance or approval of the MLI and a
specified time has passed.
Tax News June 20173
Important dates in July 2017
Tax News June 20174
Date Reporting/Payment
10 July 2017 Payment of CIT advance payment for June 2017
14 July 2017 Intrastat report
20 July 2017 EC Sales List and VAT return (only in case of IC supplies)
20 July 2017BST - Report on trade in services and part of goods, and the current/capital transfers to non-
residents for June 2017
20 July 2017 KRD - Report about received and granted loans and deposits by non-residents for June 2017
31 July 2017 VAT Return
31 July 2017SKV - Report on short-term receivables and liabilities for transaction with non-residents for June
2017
31 July 2017 PD form – Report on supplies (Article 76.a VATA-1) for June 2017
31 July 2017 1-ZAP/M Form – Monthly Report on Earnings for June 2017
31 July 2017 POSL-P/ČL – Quarterly reporting – 2nd quarter of 2017
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© 2017 Ernst & Young Svetovanje, d.o.o.All Rights Reserved.
This material has been prepared for general informational purposes only and is not intended to be relied upon as accounting, tax, or other professional advice. Please refer to your advisors for specific advice.
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Tax News June 20175
EY Slovenia – Tax Services Leaders
Dénes Szabó, Partner, Head of TaxT: +386 1 583 17 72E: [email protected]
► Dénes advises local and multinational companies on tax efficient international restructuring and mergers & acquisitions.
► He leads teams to solve local and international tax controversy issues and manages APA and tax ruling negotiations.
Iris Bajec, Senior ManagerT: +386 1 583 17 12E: [email protected]
► Iris specializes in accounting, compliance and reporting.► She has extensive experience in transaction tax and in
preparation and review of CIT returns and financial statements.
Anka Pogačnik, ManagerT: +386 1 583 17 54E: [email protected]
► Anka advises clients mainly on VAT and other indirect taxes.
► She has experience in advising clients on complex tax issues, due diligences and VAT optimisation projects.
Mojca Lukač, Senior ManagerT: +386 1 583 17 31E: [email protected]
► Mojca advises clients on personal income tax, social security, payroll and immigration.
► She has experience in HR advisory and labor law.
Matej Kovačič, Senior ManagerT: +386 1 583 17 62E: [email protected]
► Matej advises clients on corporate tax, international tax and transfer pricing.
► He has extensive experience in advising domestic and international clients on tax aspects of business restructurings, e.g. acquisitions, disposals, spin-offs, liquidations and mergers.
Lucijan Klemenčič, Senior ManagerT: +386 1 583 17 21E: [email protected]
► Lucijan assists clients in transfer pricing documentation and taxation of permanent establishments.
► He has experience advising domestic and foreign clients on tax aspects of corporate restructuring and tax auditprocedures.
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