Regulatory updates - Slovenia

On 3 March 2023, the Ministry of Finance of the Republic of Slovenia published its proposal of the government’s position to adopt the Proposal for a Council Directive amending Directive 2006/112/EC.

According to the announcement, the Republic of Slovenia supports the ViDA proposal, which:

• Updates VAT reporting obligations,
• Addresses the challenges of the platform economy, and
• Reduces the need for multiple VAT identifications for cross-border transactions in the internal market.

The Slovenian draft proposal stipulates that before the adoption by the EU institutions, the government while enabling tax authorities to control and collect the tax more effectively, will:

• Create solutions that will simplify business for companies in the internal market, and
• Reduce the compliance costs for VAT.

This proposal of the position of the Republic of Slovenia should be considered in the National Assembly until 31 March 2023.

As we reported in an earlier update, Slovenia has been at the forefront of e-invoicing in Europe as one of the earliest adopters of B2G mandatory e-invoicing following the transposition of the Directive 2014/55/EU.

In June 2021, the Ministry of Finance released a new draft law aimed at mandating e-invoices for B2B transactions.

Who is in the scope?

All persons who have the status of a business entity, budget user, or subscriber status must exchange e-invoices exclusively.

Anticipated CTC model

The draft law indicates that this will be a centralised pre-clearance with exchange via interoperability. Below is a summary of the envisioned flow:

1. The taxpayer shall create the invoice in the prescribed XML format and get it approved (cleared) with the central platform of the tax administration;
2. Upon a successful clearance, the central platform will provide the issuer with an authorisation code;
3. After that, the supplier shall exchange the e-invoice with the buyer, according to predefined interoperability standard;
4. The invoice receiver can optionally validate the invoice with the tax administration platform.

Business Register

The draft law stipulates that all entities subject to the regulation must be registered in the central e-business register.

Indicative timelines

• The draft law is currently under consideration by the Slovenian Parliament, and there is no specific timeline for when it will be approved. However, once approved, the draft law will enter into force on the fifteenth day after its publication in the Official Gazette of the Republic of Slovenia;
• Technical specifications will be published within six months from the publication of the law;
• The law provisions will be applicable within 12 months after its publication.

UJP is a single entry or exit point for the exchange of e-invoices issued and received by budget users. As one of the earliest adopters of B2G e-invoicing, this latest development follows the 2015 mandate by the Government of Slovenia requiring all suppliers to the Slovenia public sector to submit e-invoices.

The mandates apply to the following:

• Budget users, who must receive e-invoices, and issue e-invoices if the e-invoice recipient is another budget user; and
• All those who do business with budget users to send e-invoices for supplied goods and services.

e-SLOG, 'Elektronsko poslovanje slovenskega gospodarstva' (Electronic Commerce in the Slovene Economy) was initiated by the Chamber of Commerce and Industry of Slovenia. The project involved experts from more than 90 companies with the aim of preparing and implementing the standards for e-commerce of companies related to order forms, delivery notes and invoices in the XML format.

Significant changes in e-SLOG 2.0 from e-SLOG 1.6 include:

• Sending invoices with an eSignature is no longer required, as was enforced previously with eSlog 1.6;
• Consolidated invoices are no longer supported;
• It is no longer necessary to enter the recipient’s bank account number; and
• The format supports more data elements, enabling greater process automation.

While e-invoices should be received and issued by budget users only through the UJP platform, suppliers will be able to submit their invoices in three ways:

• Manually, by keying in their invoice information directly into the UJPnet portal;
• Via email, by submitting them to UJP in XML format; or
• By contracting an e-invoicing service provider that has either a direct connection with UJP or is a Peppol access point.

UJP also accepts e-invoices that comply with EN 16931-1, namely Peppol BIS 3.0.

'Slovenia has long been in the forefront of e-invoicing in Europe. We are excited to see that, with implementation of the Directive 2014/55/EU, the benefits of easy, open and transparent cross-border trade will now be possible. This change will as well benefit the local companies who would trade or plan trade with other counties or who were looking to modernise their processes,' — says Nazar Paradivskyy, VP Compliance and Interoperability at Pagero.