Slovenia advances ratification bill for Hong Kong tax treaty

Domestic approval is advancing

The Government’s 18th-session agenda identifies the proposed ratification law, while the underlying record gives it code 00704-333/2026/2 and EVA 2026-1811-0048. That record cautions that published government materials are drafts and may not be adopted in their published form. By 10 November, a State Council committee had scheduled the proposal under parliamentary identifier EPA 388-X. These records do not establish parliamentary passage, promulgation or entry into force.^[1][2][3]

Proposed withholding ceilings

The signed agreement covers Hong Kong profits, salaries and property taxes and Slovenia’s corporate and individual income taxes. Article 10 would cap source-country tax on dividends at 5% where the beneficial owner is a company holding directly at least 10% of the payer’s capital throughout a 365-day period including the payment date; the cap would otherwise be 10%. Articles 11 and 12 would cap qualifying interest and royalties at 5%. Payments effectively connected with a permanent establishment remain governed by the business-profits rules.^[4]

Benefits depend on entry into force and anti-abuse tests

The treaty contains a principal-purpose test capable of denying a benefit where obtaining it was one of the principal purposes of an arrangement or transaction, unless granting the benefit accords with the relevant provisions’ object and purpose. Article 28 requires both jurisdictions to notify completion of their domestic procedures; entry into force occurs on the later notification. It would then apply in Hong Kong for years of assessment beginning on or after 1 April of the following calendar year and in Slovenia from 1 January of the following calendar year for withholding and other income taxes.^[4]

No treaty rate is available yet

Hong Kong’s Inland Revenue Department records its section 49 Order as in progress and entry into force and effective date as pending. Groups should identify Slovenia–Hong Kong dividend, interest and royalty flows without applying treaty rates. Relevant facts include residence and beneficial ownership, direct capital percentage and holding history, any permanent-establishment connection, and arrangements relevant to the principal-purpose test.^[4][5]

The proposal creates no current filing, payment or remittance deadline. Monitoring should continue for Slovenian enactment, Hong Kong’s section 49 Order, completion notifications and the resulting first applicable periods.^[1][3][5]