Chapter DT17102

Published date20 May 2016
Record NumberDT17102

The table summarises the provisions of the treaty in force. Where a percentage rate is shown, this rate is the ‘treaty rate’ and does not reflect taxes chargeable under the domestic law of either state before relief is given under the provisions of the treaty. The ‘treaty rate’ is the maximum rate at which the UK and Slovenia are permitted to tax income in the relevant categories under the treaty. Rates chargeable under the domestic law of either state may be higher or lower.

In all cases other conditions for relief (e.g. beneficial ownership) will have to be met before relief is due under the treaty. The text of the treaty itself should be consulted for the full details.

Subjects Comments Article
Portfolio dividends 15% 10
Dividends on direct investments 0% 10
Conditions for lower rate on dividends on direct investments The beneficial owner is a company which holds directly at least 20 per cent of the capital of the company paying the dividends. 10
Property income dividends 15% 10
Interest 5% (note 1) 11
Royalties 5% 12
Government pensions Taxable only in Slovenia unless the individual is a resident of and national of the UK 18
Other pensions Taxable only in the UK 17
Arbitration Yes (note 2) Under MLI

Note 1: Interest is taxable only in the UK where such interest is paid:

  • to the UK Government, a political subdivision or a local authority of the UK Government
  • in respect of a loan made, guaranteed or insured, or any other...

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