Slovenia introduces optional VAT groups under ZDDV-1O, available from 1 January 2026

What changed in detail

The Act amending the Value Added Tax Act (ZDDV-1O), published in Uradni list RS No. 104/2024 on 10 December 2024, used the option in Article 11 of the VAT Directive and added a VAT grouping regime to ZDDV-1 as Article 5.a. The regime has applied since 1 January 2026.

As described by the financial administration (FURS):

• two or more taxable persons established in Slovenia, or a fixed establishment in Slovenia (a branch entered in the Slovenian court register), may be treated as one taxable person;
• they must be financially, economically and organisationally linked, all three at once and continuously; financial links mean more than 50% of the capital or voting rights;
• one member acts as the group’s representative and applies on form DDV-P2s through eDavki, with the consent of every joining member, for a single VAT identification number;
• transactions between group members are not subject to VAT, and invoices between members are not VAT invoices;
• the group’s tax period is the calendar month, and members are jointly and severally liable for the VAT arising from their membership.

What it means

Membership is optional. Groups with significant intra-group service flows, especially where some members cannot fully deduct VAT, such as financial or insurance businesses, can take those flows out of VAT altogether. The cost is joint liability and a group-wide deduction position, so the decision is not purely administrative.

The regime has been available since 1 January 2026 and remains in force. The same Act raised the small-business threshold, recorded in a separate record.