Who is actually obliged to pay income tax in Slovenia

A digital nomad's tax regime is determined not by the type of permit but by the provisions of the Personal Income Tax Act (ZDoh-2) and applicable international treaties. Under Article 5 of ZDoh-2:

  • a resident pays tax on all worldwide income — in Slovenia and abroad.
  • a non-resident pays tax only on income whose source is in Slovenia.

The first key question when planning is to determine your tax status.

When a digital nomad becomes a tax resident

Article 6 of ZDoh-2 sets the criteria for residency, and meeting at least one of them is enough to be recognised as a resident:

  • a permanent registered place of residence in Slovenia;
  • a usual place of residence in the country;
  • the centre of personal and economic interests is in Slovenia;
  • a stay in the country of more than 183 days in a calendar year;
  • other substantial ties with Slovenia.

The 183-day rule is an important but not the only criterion. If a person moves to Slovenia with their family, rents permanent housing, transfers their children to a Slovenian school and shifts their centre of life interests here, tax residency can arise even before 183 days pass.

Slovenian tax residents are obliged to declare worldwide income — both received in Slovenia and abroad.

What if you spend less than 183 days in Slovenia

A stay of less than 183 days does not mean an automatic absence of tax obligations. Article 9 of ZDoh-2 directly provides: income from employment is considered to be received in Slovenia if the work is actually performed on the territory of the country.

This is a fundamentally important rule: even if the employer is foreign, the salary is paid outside Slovenia and the contract is under foreign law — but the work is physically performed from the territory of Slovenia, the income may be recognised as income from a Slovenian source. And a non-resident is obliged to pay tax precisely on income from a Slovenian source (Art. 5 of ZDoh-2).

International treaties and conditions for tax exemption

Exemption from taxation in Slovenia is only possible where there is a double taxation treaty in force. As a rule, the article on income from employment applies, which provides for three conditions — and all of them must be met at the same time:

  1. the employee is present in Slovenia for no more than 183 days in the period set by the relevant international treaty;
  2. the remuneration is paid by an employer who is not a tax resident of Slovenia;
  3. the cost of the salary is not borne by the employer's permanent establishment in Slovenia.

Exemption is not applied automatically — you have to claim the right to it at FURS (the Financial Administration of Slovenia) and confirm it with documents, including a certificate of tax residency in another state and the employment contract.

Specifics for citizens of the Russian Federation

Between the Russian Federation and the Republic of Slovenia there is a Double Taxation Treaty of 29 May 1995 (in force from 29 August 1996), Article 15 of which provided for the 183-day rule.

However, by Decree of the President of the Russian Federation No. 585 of 8 August 2023, the application of the provisions of this treaty was suspended by the Russian Federation, including the provisions of Article 15. The practical consequence:

  • the exemption mechanism under the 183-day rule in RF–Slovenia relations does not currently apply;
  • if income is recognised as income from a source in Slovenia (Art. 9 of ZDoh-2), it is taxed in Slovenia under domestic law;
  • the question of eliminating double taxation shifts to the country of tax residency — for example, through a foreign tax credit mechanism under its national law.

What happens after being recognised as a tax resident

After being recognised as a tax resident of Slovenia, a person must declare their foreign salary and other foreign income here. Slovenian income tax is calculated on a progressive scale, and the final amount depends on:

  • annual income and the type of remuneration received;
  • the amount of social contributions;
  • applicable tax allowances and family composition;
  • tax already paid in another country;
  • the provisions of the double taxation treaty.

Foreign tax can, in certain cases, be credited when calculating the Slovenian tax — for this you need to declare the income correctly and provide documents confirming the final payment of tax abroad.

Taxes for entrepreneurs and the self-employed

For entrepreneurs the tax situation is more complex than for employees. According to FURS guidance, a tax resident of Slovenia who actually carries out independent activity from the country must register the activity in Slovenia and declare income on the worldwide income principle. Obligations can also arise for a non-resident if the activity is actually carried out on the territory of Slovenia.

Depending on the situation, the following may be required:

  • registering the activity in Slovenia and obtaining a Slovenian tax number;
  • registering a foreign company or its branch;
  • filing tax returns and paying advance tax;
  • registering in the VAT system;
  • paying social contributions.

The risk of a foreign company's permanent establishment

If the owner or an employee of a foreign company constantly manages the business from Slovenia, the company may create a permanent establishment (PE). The risk increases if, from Slovenia:

  • contracts are regularly concluded;
  • key management decisions are made;
  • negotiations with clients are conducted;
  • the company's core activity is carried out;
  • a permanent workplace is used or the actual management of the business is located.

In this case tax obligations can arise not only for the digital nomad but for their foreign company. This question needs to be checked especially carefully by company owners, directors, consultants and entrepreneurs who plan to be in Slovenia for most of the year.

Do you need to pay social contributions

Income tax and social contributions are regulated separately. The obligation to pay social contributions in Slovenia depends on:

  • the country where the employer is registered and the type of contract;
  • the existence of social insurance abroad;
  • an international social security agreement;
  • the duration of the work in Slovenia;
  • the status of employee or self-employed person.

If the Slovenian social insurance system applies to an employee of a foreign company, they may be obliged to register themselves, file calculations and pay both their own contributions and the contributions usually considered the employer's obligation.

Three typical situations

Working in Slovenia for a few months

A person comes alone for three or four months, keeping their housing, family and tax residency in another country. With a valid tax treaty and all the conditions for short-term work met, the income may remain taxable only in the country of tax residency — but the right to exemption has to be confirmed at FURS.

The whole family moving for a year

The spouses move to Slovenia, rent permanent housing, the children start attending school or kindergarten. In this situation the centre of life interests can shift to Slovenia, and tax residency can arise even before 183 days pass.

Managing a foreign business from Slovenia

A company owner constantly works from a flat or office in Ljubljana, holds negotiations and makes management decisions. Besides personal tax obligations, this creates the risk of a foreign company's permanent establishment and the need to register the activity in Slovenia.

How to arrange a digital nomad permit without tax mistakes

Before applying for digital nomad status it is worth checking not only the existence of a foreign contract and sufficient income but the whole structure of the work:

  • who is actually the employer or client and where the payer of the income is registered;
  • whether remote work is allowed and how the actual payments are confirmed;
  • where the applicant will remain a tax resident;
  • whether an obligation to pay social contributions arises;
  • whether a foreign company's permanent establishment arises.

The grounds and requirements for the digital nomad permit itself are on the Slovenia digital nomad permit page. A general overview of the country's tax system is in the article taxes in Slovenia: a full guide.

The information is current for 2026. The required income and the tax obligations need to be checked immediately before applying — taking into account the latest official publication and the applicant's individual situation.