Slovenia has implemented a new general anti-abuse rule (GAAR) and controlled foreign company (CFC) rules in compliance with the EU Anti-Tax Avoidance Directive. The new rules are implemented through amendments to Slovenia's Corporate Tax Act (the Act)
GAAR
The new GAAR provides that when determining a taxpayer's tax liability, and in particular the recognition of a tax benefit or entitlement under the Act, the tax authority may disregard a non-genuine arrangement or series of arrangements…