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Slovenia Publishes Synthesized Texts of Tax Treaties with Russia and South Korea as Impacted by the BEPS MLI — Orbitax Tax News & Alerts

Slovenia's Ministry of Finance has published the synthesized texts of the 1995 tax treaty with Russia and the 2005 tax treaty with South Korea as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaties and the MLI take precedence and remain the legal texts applicable.

The provisions of the MLI have effect with respect to the 1995 Slovenia-Russia 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 2021;
  • with respect to all other taxes levied by Slovenia, for taxes levied with respect to taxable periods beginning on or after 30 November 2020; and
  • with respect to all other taxes levied by Russia, for taxes levied with respect to taxable periods beginning on or after 1 January 2021.

The provisions of the MLI have effect with respect to the 2005 Slovenia-South Korea 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 2021; and
  • with respect to all other taxes levied by each Contracting State, for taxes levied with respect to taxable periods beginning on or after 1 March 2021.

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