Slovenia Amending Corporate Income Tax Act in Relation to Permanent Establishments, Capital Gains, and Interest Deduction Restrictions

Slovenia's Ministry of Finance has published the draft Act on Amendments and Supplements to the Corporate Income Tax Act. The measures include

• New rules to limit the avoidance of permanent establishment (PE) status through commissionaire arrangements and similar strategies;
• A reduction in the activity period for a construction PE to be considered constituted from 12 months to 6 months;
• New rules to limit the avoidance of PE status through splitting-up of activities to take advantage of exce…