II. TAXABLE PERSON AND TAX LIABILITY

(1) The tax liability may be established on the basis of group taxation.

Tax obligations

(Scope of the tax liability)

(3) In the cases referred to in points 2, 3, 4 and 5 of the second paragraph of this Article, the tax liability established on the basis of the group tax calculation shall be abolished and the group members` individual liability shall be established, as if there were no group taxation.

(2) As regards group taxation, the profit and loss for the tax period with regard to which the tax liability is established which is determined, in compliance with this Act, on the basis of individual tax calculations of the members of the group shall be added together.

For the purposes of this Article ` a higher tax obligation of the company` means the imposition of new taxes, charges and duties and/or other similar payments and/or increase in tax rates and in the amount of charges and duties and/or other similar payments.

This Agreement shall not affect the rights and obligations of the Parties under any tax convention.

(ii) government revenue that is otherwise due is foregone or not collected (e.g. fiscal incentives such as tax credits) [72];

In September 2003, the social partners will examine the possibilities for establishing extraordinary reduction of tax obligations in 2004 for persons in the lowest income brackets.

The transfers referred to in Article 4, 5, 6 and 7 shall be effected without undue delay and, at all events, within three months after all tax obligations have been met, and shall be made in a convertible currency.

b a person liable to tax obtains a reduction in or an exemption from tax in the first-mentioned Party which would give rise to an increase in tax or to liability to tax in the other Party;

Recognising that international co-operation can play an important part in facilitating the proper determination of tax liabilities and in helping the taxpayer to secure his rights;

e information forwarded to the first-mentioned Party by the other Party has enabled information to be obtained which may be relevant in assessing liability to tax in the latter Party.

The tax obligations under the previous paragraph are deemed to be complied with when the investor has fulfilled the proceedings provided for by the law of the Contracting Party on the territory of which the investment has been carried out.

In order to address the needs of different generations, take numerous measures, including fiscal measures, to improve the possibilities for combining professional life with family obligations.

Any two or more Parties may mutually agree that the Convention, as amended by the 2010 Protocol, shall have effect for administrative assistance related to earlier taxable periods or charges to tax.

(1) A taxable person claiming a deduction subject to Article 55 of this Act shall present evidence containing the data about the tax liability outside Slovenia, the amount of the tax on foreign income, the basis for the tax and the amount of the tax paid.

(3) The taxable person` s liability referred to in the first and second paragraphs of this Article relating to the payment of the tax on the basis of the tax calculation for an individual tax period shall, in the manner laid down in this Act or the act regulating the tax procedure, be reduced by the paid amount of the tax withheld.

This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status of family responsibilities which it grants to its own residents.

This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, reliefs and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.

However, if subsequent changes of the law in the Republic of Slovenia in the field of taxation would result in a higher tax obligation of the company, the Slovenian Party shall promptly, adequately and effectively compensate the company for the difference between the amount of the after-tax profit, which would have been obtained before changes of the law in the Republic of Slovenia in the field of taxation or the amount of the reasonable after-tax profit in this sector, whichever of these amounts is lower, and the amount of the reduced after-tax profit actually obtained after changes of the law.

3 The obligation to provide assistance in the recovery of tax claims concerning a deceased person or his estate, is limited to the value of the estate or of the property acquired by each beneficiary of the estate, according to whether the claim is to be recovered from the estate or from the beneficiaries thereof.

(2) If the transferring company alienates the received securities prior to the expiry of the period referred to in the first paragraph of this Article, it shall be deemed that the condition of the duration of participation was not met, unless the transferring company and the receiving company prove that the main purpose or one of the main purposes of the transfer of activities was not avoiding tax liabilities.

` f to apply paragraph 7 of Article 28 exclusively for administrative assistance related to taxable periods beginning on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the third year preceding the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.`

6 The provisions of this Convention, as amended by the 2010 Protocol, shall have effect for administrative assistance related to taxable periods beginning on or after 1 January of the year following the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party, or where there is no taxable period, for administrative assistance related to charges to tax arising on or after 1 January of the year following the one in which the Convention, as amended by the 2010 Protocol, entered into force in respect of a Party.

7 Notwithstanding paragraph 6, for tax matters involving intentional conduct which is liable to prosecution under the criminal laws of the applicant Party, the provisions of this Convention, as amended by the 2010 Protocol, shall have effect from the date of entry into force in respect of a Party in relation to earlier taxable periods or charges to tax.`

The obligation to pay the tax subject to the tax calculation relating to an individual tax period as regards the income earned by residents and non-residents through the activities conducted in or through the place of establishment in Slovenia shall, in a manner laid down by this Act or the act regulating the tax procedure, be reduced by the tax prepayment paid.

b) determine the tax liability in accordance with Articles 63 to 67 of this Act, where the change method of determining shall not be deemed a definition of individual taxation, and the members do not comply with the sixth paragraph of Article 200 of the Tax Procedure Act (Uradni list RS, Nos. 18/96, 78/96, 87/97, 35/98, 76/98, 82/98, 91/98, 1/99, 108/99, 37/01, 97/01, 52/02, and 33/03).

A resident may deduct from his obligation to pay the tax subject to the tax calculation relating to an individual tax period the amount equalling the tax corresponding to the tax subject to this Act which was paid by him with regard to the income whose sources are outside Slovenia (hereinafter: foreign tax) with regard to the income whose sources are outside Slovenia (hereinafter: foreign income) which is included in his tax basis.

(2) A dividend paid out to a person who has not yet met the condition of 24 months subject to point 2 of the first paragraph of this Article but, however, meets the conditions referred to in the first paragraph of this Article may be paid out without withholding tax provided that the payer of the dividend or a mediator provides an appropriate bank guarantee, in order to secure the meeting of a possible tax liability, to the responsible tax authority.

Considering that fundamental principles entitling every person to have his rights and obligations determined in accordance with a proper legal procedure should be recognised as applying to tax matters in all States and that States should endeavour to protect the legitimate interests of taxpayers, including appropriate protection against discrimination and double taxation;

Without prejudice to the exonerations provided for in Articles 22 and 23 of the Convention, when the Organisation in the exercise of its official activities makes substantial acquisitions of property or employs services of substantial value in respect of which indirect duties, taxes or charges (including such duties, taxes or charges levied on importation other than those referred to in Article 23.1 of the Convention) have been paid or are payable, the Governments of the Member States shall, whenever possible, take appropriate action to offset the effect on the Organisation of such duties, taxes or charges by means of an adjustment of the financial contributions to the Organisation or by means of remission or of reimbursement to the Organisation of the amount of the duties, taxes or charges.

This financial contribution confers a benefit to the recipient by reducing its income tax liability.

The measurement of minority interests and deferred tax follows from the measurement of other assets and liabilities.

Therefore, the above adjustments to recognised assets and liabilities affect minority interests and deferred tax.

According to the information available, it can indeed not be excluded that these grants, at a later stage, may increase a company's overall tax liability.

Several companies submitted that the sales of their DEPB licences would generate additional income, and thereby increase their overall tax liability, most notably company income tax.

The tax administration shall bring to the attention of VAT-registered traders the obligations which they may incur as parties responsible for providing the information required by Intrastat.

A merger or division shall not give rise to any taxation of capital gains calculated by reference to the difference between the real values of the assets and liabilities transferred and their values for tax purposes.

Such factors do not only relate to pricing and sales issues, but also concern other issues that determine overall tax liability, such as decisions concerning depreciation rates, the carrying forward of losses and many other factors.

residents of the other Contracting State any personal allowances, reliefs and reductions for tax purposes on account of civil status or family responsibilities which it grants to its own residents; or

transferred assets and liabilities: those assets and liabilities of the transferring company which, in consequence of the merger or division, are effectively connected with a permanent establishment of the receiving company in the Member State of the transferring company and play a part in generating the profits or losses taken into account for tax purposes.

value for tax purposes: the value on the basis of which any gain or loss would have been computed for the purposes of tax upon the income, profits or capital gains of the transferring company if such assets or liabilities had been sold at the time of the merger or division but independently of it,

It shall reclassify that item (and, if any, the related deferred tax and minority interests) as part of goodwill (unless it deducted goodwill directly from equity under previous GAAP, see paragraph B2(g)(i) and B2(i)).

This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, relief and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.

This provision shall not be construed as obliging a Contracting State to grant to residents of the other Contracting State any personal allowances, relieves and reductions for taxation purposes on account of civil status or family responsibilities which it grants to its own residents.

In the current case, the amount of tax normally payable during the IP is the tax payable during the tax year 2002 (no data regarding any tax payable amount concerning the first three months of the tax year 2003 being available during the on-spot investigation), and these taxes due are incurred in respect of revenue earned in 2001.

This condition shall be proved by the acts on establishment of the company; 3. if the activity in the economic zone will increase the total number of employees; 4. the operator and the persons who establish a legal entity or a branch in the economic zone have no outstanding mature tax or customs liabilities and are not prosecuted due to an offence or a suspected criminal act connected with the performance of the economic activity.

Similarly, if paragraph B2(f) requires the first-time adopter to recognise an intangible asset that was subsumed in recognised goodwill under previous GAAP, the first-time adopter shall decrease the carrying amount of goodwill accordingly (and, if applicable, adjust deferred tax and minority interests).