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HMRC internal manual

Double Taxation Relief Manual

Slovenia - Interest

Interest arising in Slovenia and paid to a resident of the United Kingdom who is the beneficial owner of the interest is taxable in Slovenia at a rate not exceeding 5% (Article 11(2)).

Interest arising in Slovenia and paid to a United Kingdom resident is, however, exempt from Slovenian tax if:

  • the payer of the interest is the Government of Slovenia or the recipient is the Government of the United Kingdom or a political subdivision, local authority or statutory body thereof (Article 11(3)(a)); or
  • the interest is paid in respect of a loan or any other debt-claim or credit made, guaranteed or insured by the United Kingdom Export Credit Guarantee Department (Article 11(3)(b)) or The Bank of England (Article 11(3)(c)); or
  • the payer and the recipient are connected companies (20% shareholding is the level required to obtain exemption)Where, however, the interest is effectively connected with a permanent establishment which the United Kingdom resident recipient has in Slovenia, the provisions of the Business profits Article (Article 7) will apply.