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Slovenia Publishes Synthesized Texts of Tax Treaties with Finland and Ireland as Impacted by BEPS MLI — Orbitax Tax News & Alerts

Slovenia's Ministry of Finance has published the synthesized texts of the 2003 tax treaty with Finland and the 2002 tax treaty with Ireland as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The documents were prepared on the basis of the MLI position of the Republic of Slovenia submitted to the Depositary on 22 March 2018 and the MLI positions of Finland and Ireland submitted to the Depositary on 25 February 2019 and 29 January 2019, respectively.

The provisions of the MLI have effect with respect to the Finland-Slovenia tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020; and
  • with respect to all other taxes levied by Finland, for taxes levied with respect to taxable periods beginning on or after 1 January 2020;
  • with respect to all other taxes levied by Slovenia, for taxes levied with respect to taxable periods beginning on or after 1 December 2019; and
  • with respect to arbitration, for cases submitted from 1 June 2019 and for cases submitted prior to that date to the extent agreed to by the competent authorities of both Contracting States.

The provisions of the MLI have effect with respect to the Ireland-Slovenia tax treaty:

  • with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2020;
  • with respect to all other taxes levied by each Contracting State, for taxes levied with respect to taxable periods beginning on or after 1 November 2019; and
  • with respect to arbitration, for cases submitted from 1 May 2019 and for cases submitted prior to that date to the extent agreed to by the competent authorities of both Contracting States.

Click the following link for the Ministry of Finance treaty webpage that includes the synthesized texts of Slovenia's treaties.