## 1.  Sustained Higher Growth is Needed for Income Convergence

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---

### Introduction — case for reform and growth
- Slovenia recovered since the 2012–13 banking crisis with growth above the euro area average.
- Income inequality: GINI index at 0.24 versus OECD average of 0.32.
- Income level remains below the EU average; accelerating income convergence requires sustained strong growth.
- Ageing is estimated to reduce productivity growth by about 0.5 percentage points during 2014–35.
- Slovenia faces one of the highest increases in age-related public spending in the medium- to long-term, creating pressure for more efficient tax and social security systems.

### Key fiscal and revenue statistics
- 2016 tax-to-GDP ratio: 36.6 percent (between OECD average of 34.3 and EU average of 38.9 percent).
- Excluding social security contributions (SSC), Slovenia’s tax ratio: 22 percent of GDP.
- SSC raise an additional 14.8 percent of GDP, making Slovenia the 6th heaviest SSC-burdened economy in the EU.
- Consumption tax revenues in 2016: 14.3 percent of GDP.
- SSC in 2016: 14.5 percent of GDP.
- Taxes on income, profits, and capital gains (natural and legal persons) in 2016: 6.8 percent of GDP (OECD average: 11.3 percent of GDP).
- Recurrent immovable property tax revenues: 0.6 percent of GDP (OECD average: 1.9 percent of GDP).
- Slovenia is ranked 23 in property tax collections in EU-28.
- Environmental taxes (excises): Slovenia is a top revenue performer among OECD member states.

### Impact of ageing and productivity
- Rapid ageing reduces the size of the productive labor force and productivity growth.
- Projections indicate substantial future age-related spending increases, underscoring the need for growth to preserve fiscal sustainability.

### Model-based finding
- Model simulations show that shifting the tax burden from labor to consumption would increase Slovenia’s output level by 0.5 percent in the medium- to long-term.

### VAT structure and performance
- Total revenue forgone from Slovenia’s expansive list of 22 reduced VAT rate supplies is 1.85 percent of GDP (2017).
- In 2016, indirect taxes raised revenues equal to 14.7 percent of GDP.
- VAT contributed 8.2 percent of GDP.
- Slovenia’s standard VAT rate is 22 percent.
- Reduced VAT rate is 9.5 percent on the 22 listed goods and services.
- Increasing the standard VAT rate above 22 percent is described as unrealistic because globally there are only 11 countries out of 160 VAT-raising jurisdictions with higher VAT rates.
- Austria’s standard VAT rate is 20 percent, which makes cross-border shopping avoidance attractive.
- Slovenia ranks about 10th place among EU-28 countries according to VAT gap studies by MoF.
- An extensive application of the reduced VAT rate is noted as neither good social nor tax policy; multiple rates increase risk of non-compliance and tax evasion and may require a higher standard rate.

### Policy recommendation on VAT
- Narrow down the range of 22 reduced-rate (9.5 percent) goods and services to create revenue gains instead of raising the standard VAT rate.

### Property tax
- Current property taxes are raised on reinstated pre-2014 legislation after attempts to introduce a market value-based real estate tax were held unconstitutional in 2014.
- Revenues from property tax show no buoyancy, raising no more than 0.5 percent of GDP.
- Revenues from the transfer tax on immovable property transactions add another 0.2 percent of GDP.
- Consideration: A value-based property tax would raise revenue potential, buoyancy and transparency.
- Noted issues: considerable differences in tax burden between municipalities and within municipalities for different groups of real estate; regime is neither transparent nor equitable.
- Progress: improvements in land registration systems and valuation methodologies will support introduction of a new property tax.

### Capital gains tax
- Capital gains attract a flat withholding tax at 25 percent on all income from capital.
- Taper relief provisions reduce the 25 percent rate for every completed five-year period of ownership, to 0 percent after 20 years.
- Primary residences are CGT exempt.
- Assessment: Taper relief undermines the fairness principle of taxation and is very beneficial to high-income households.
- Best practice suggestions:
  - Treat short-term capital gains realized within one year of acquisition as ordinary revenue taxed at the applicable marginal PIT rate or tax them at the flat proportional rate of the DIT.
  - Accommodate inflationary gain element by indexing asset value for inflation, or by gradually reducing the inclusion of gain by a certain percentage for each year of holding the asset.

### Simulation of tax reform impact (GIMF-based)
- Reform design parameters:
  - Cut in the rate of social security contribution by about 5 percentage points offset with increased collections from consumption tax.
  - This tax rebalancing would reduce labor tax by about 1.2 percent of GDP in 2017.
- To achieve ex-ante revenue neutrality:
  - Increased effective collections from the consumption tax by about 1 percent of GDP.
  - Other lump-sum tax increase by about 0.2 percent of GDP (e.g., reducing tax expenditures and broadening tax base).
- Model: IMF’s Global Integrated Monetary and Fiscal model (GIMF) used to simulate general equilibrium effects; calibrated for Slovenia.
- Revenue coverage assumption: 70 percent of the income tax decline is covered by consumption taxes; the rest is financed by lump-sum taxes approximating effects of inheritance or property taxes.
- Fiscal stance: Deficit-to-GDP target kept unchanged; small deviations average out and debt-to-GDP remains roughly unchanged.

### Simulation results and macroeconomic effects
- Permanent increase in Slovenia’s output level by 0.5 percent in the medium- to long-term from shifting tax burden from labor to consumption.
- Mechanism: Lower labor taxation increases private consumption and aggregate labor, raising real output; depreciation of real effective exchange rate supports exports and discourages imports; long-run equilibrium with higher labor input, higher capital stock, and higher net foreign assets.
- Short- and medium-term dynamics:
  - Consumption would decline marginally in a couple of years after the reform when consumption tax is increased, then rebound to a higher level in the medium term.
  - Temporary consumption decline would reduce tax collections and contribute to a marginally higher deficit, with government debt rising by less than 0.1 percentage point.
  - In the medium- to long-term, fiscal revenue would be higher and government debt lower by about 0.15 percentage point.
- Timing and complementarities:
  - Positive effects are largest in the medium- and long-term and are reached gradually.
  - Timing should consider the position in an economic cycle and other public spending reforms.
  - The current economic recovery with a positive output gap is noted as a good opportunity to consider such a reform.
  - Amplification and mitigation: Positive impact can be amplified and short-term adverse impact minimized when combined with other growth-enhancing structural reforms (reforming state-owned enterprises; enhancing labor market flexibility and labor quality for younger and elder workers; improving product and service markets).

### SME taxation — key points and regime options
- SMEs are diverse; small and micro enterprises constitute between 85–95 percent of business taxpayers but contribute mostly small tax revenue.
- SME taxation should be treated as a special case and coherently include business income taxpayers below the VAT registration threshold.
- Rationale for special SME treatment: preserve employment, increase horizontal and vertical equity, enhance economic efficiency, support tax morale, and improve government accountability and transparency.

Regime options described:
- Indicator-based patent tax regime:
  - Substitutes for income tax and social contributions for micro or sole traders.
  - Fixed fee across activities; simple; no bookkeeping required; regressive; encourages formalization but may hinder growth due to compliance burdens when migrating.
- Presumptive taxation based on indicators:
  - Uses physical indicators or financial information as proxy income indicators.
  - Little bookkeeping; potential complexity and cross-sector incomparability; may create distortions versus general regime.
- Turnover-based SME taxation:
  - Available to firms under the VAT registration threshold.
  - Flat tax of say 3-5 percent on gross receipts in lieu of income taxation.
  - Effective tax rate varies inversely with profit margins; requires simple bookkeeping (record sales).
- Cash-flow based presumptive tax:
  - Single-entry bookkeeping; offsets gross receipts against total expenditures/costs with immediate expensing of capital expenditure.
  - Replaces income tax and achieves equal effective tax rates across sectors.

Tax design and avoidance challenges:
- Presumptive regimes encourage splitting of businesses to benefit from lower effective rates.
- Lower SME regime burdens relative to wage tax can induce conversion of employees into independent contractors.
- Low compliance standards in SME regimes complicate verification of tax facts and provide opportunities to remain in the shadow economy.

### VAT registration threshold and SME tax regime
- Use a well-considered VAT registration threshold as the cutoff turnover threshold for the SME tax regime to ensure medium-sized businesses are subject to the general tax regime.
- Clarify the thresholds between micro and small businesses when only turnover is the criterion for differentiation.
- Firms requiring VAT registration (as turnover exceeds the VAT registration threshold) should attract the general income tax.
- Reordering thresholds will facilitate migration into the general regime.

### Treatment of professional services
- Exclude any professional service from the SME regime.
- Exclusion allows for streamlined and synchronized VAT returns, CIT filing, and tax payment obligations.

### Tax administration: audits, filing support, and SME assistance
- Provide special audit and tax filing support by the tax administration to SMEs to shore up trust and tax morale.
- Conduct risk-based tax audits of presumptive taxpayers, addressing abuse by large taxpayers.
- Implement SME assistance and advisory programs focused on improving SMEs bookkeeping standards to encourage compliance.

*Prepared by Michal Andrle, Larry Qiang Cui, Martin Grote, and Jens Reinke. January 29, 2019.*

### 1.  Sustained Higher Growth is Needed for Income Convergence ______________________ 2

### 1.  Sustained Higher Growth is Needed for Income Convergence

### Introduction — case for reform and growth
- Slovenia recovered since the 2012–13 banking crisis with growth above the euro area average.
- Income inequality: GINI index at 0.24 versus OECD average of 0.32.
- Income level remains below the EU average; accelerating income convergence requires sustained strong growth.
- Ageing is estimated to reduce productivity growth by about 0.5 percentage points during 2014–35.
- Slovenia faces one of the highest increases in age-related public spending in the medium- to long-term, creating pressure for more efficient tax and social security systems.

### Key fiscal and revenue statistics
- 2016 tax-to-GDP ratio: 36.6 percent (between OECD average of 34.3 and EU average of 38.9 percent).
- Excluding social security contributions (SSC), Slovenia’s tax ratio: 22 percent of GDP.
- SSC raise an additional 14.8 percent of GDP, making Slovenia the 6th heaviest SSC-burdened economy in the EU.
- Consumption tax revenues in 2016: 14.3 percent of GDP.
- SSC in 2016: 14.5 percent of GDP.
- Taxes on income, profits, and capital gains (natural and legal persons) in 2016: 6.8 percent of GDP (OECD average: 11.3 percent of GDP).
- Recurrent immovable property tax revenues: 0.6 percent of GDP (OECD average: 1.9 percent of GDP).
- Slovenia is ranked 23 in property tax collections in EU-28.
- Environmental taxes (excises): Slovenia is a top revenue performer among OECD member states.

### Impact of ageing and productivity
- Rapid ageing reduces the size of the productive labor force and productivity growth.
- Projections indicate substantial future age-related spending increases, underscoring the need for growth to preserve fiscal sustainability.

### Model-based finding
- Model simulations show that shifting the tax burden from labor to consumption would increase Slovenia’s output level by 0.5 percent in the medium- to long-term.

### Source attribution
*Prepared by Michal Andrle, Larry Qiang Cui, Martin Grote, and Jens Reinke. January 29, 2019.*

### 17.      The applicability of reduced VAT rates should be narrowed. Despite its high headline

### 17.      The applicability of reduced VAT rates should be narrowed. Despite its high headline

### VAT structure and performance
- Total revenue forgone from Slovenia’s expansive list of 22 reduced VAT rate supplies is 1.85 percent of GDP (2017).
- In 2016, indirect taxes raised revenues equal to 14.7 percent of GDP.
- VAT contributed 8.2 percent of GDP.
- Slovenia’s standard VAT rate is 22 percent.
- Reduced VAT rate is 9.5 percent on the 22 listed goods and services.
- Increasing the standard VAT rate above 22 percent is described as unrealistic because globally there are only 11 countries out of 160 VAT-raising jurisdictions with higher VAT rates.
- Austria’s standard VAT rate is 20 percent, which makes cross-border shopping avoidance attractive.
- Slovenia ranks about 10th place among EU-28 countries according to VAT gap studies by MoF.
- An extensive application of the reduced VAT rate is noted as neither good social nor tax policy; multiple rates increase risk of non-compliance and tax evasion and may require a higher standard rate.

### Policy recommendation on VAT
- Narrow down the range of 22 reduced-rate (9.5 percent) goods and services to create revenue gains instead of raising the standard VAT rate.

### Property tax
- Current property taxes are raised on reinstated pre-2014 legislation after attempts to introduce a market value-based real estate tax were held unconstitutional in 2014.
- Revenues from property tax show no buoyancy, raising no more than 0.5 percent of GDP.
- Revenues from the transfer tax on immovable property transactions add another 0.2 percent of GDP.
- Consideration: A value-based property tax would raise revenue potential, buoyancy and transparency.
- Noted issues: considerable differences in tax burden between municipalities and within municipalities for different groups of real estate; regime is neither transparent nor equitable.
- Progress: improvements in land registration systems and valuation methodologies will support introduction of a new property tax.

### Capital gains tax
- Capital gains attract a flat withholding tax at 25 percent on all income from capital.
- Taper relief provisions reduce the 25 percent rate for every completed five-year period of ownership, to 0 percent after 20 years.
- Primary residences are CGT exempt.
- Assessment: Taper relief undermines the fairness principle of taxation and is very beneficial to high-income households.
- Best practice suggestions:
  - Treat short-term capital gains realized within one year of acquisition as ordinary revenue taxed at the applicable marginal PIT rate or tax them at the flat proportional rate of the DIT.
  - Accommodate inflationary gain element by indexing asset value for inflation, or by gradually reducing the inclusion of gain by a certain percentage for each year of holding the asset.

### Simulation of tax reform impact (GIMF-based)
- Reform design parameters:
  - Cut in the rate of social security contribution by about 5 percentage points offset with increased collections from consumption tax.
  - This tax rebalancing would reduce labor tax by about 1.2 percent of GDP in 2017.
- To achieve ex-ante revenue neutrality:
  - Increased effective collections from the consumption tax by about 1 percent of GDP.
  - Other lump-sum tax increase by about 0.2 percent of GDP (e.g., reducing tax expenditures and broadening tax base).
- Model: IMF’s Global Integrated Monetary and Fiscal model (GIMF) used to simulate general equilibrium effects; calibrated for Slovenia.
- Revenue coverage assumption: 70 percent of the income tax decline is covered by consumption taxes; the rest is financed by lump-sum taxes approximating effects of inheritance or property taxes.
- Fiscal stance: Deficit-to-GDP target kept unchanged; small deviations average out and debt-to-GDP remains roughly unchanged.

### Simulation results and macroeconomic effects
- Permanent increase in Slovenia’s output level by 0.5 percent in the medium- to long-term from shifting tax burden from labor to consumption.
- Mechanism: Lower labor taxation increases private consumption and aggregate labor, raising real output; depreciation of real effective exchange rate supports exports and discourages imports; long-run equilibrium with higher labor input, higher capital stock, and higher net foreign assets.
- Short- and medium-term dynamics:
  - Consumption would decline marginally in a couple of years after the reform when consumption tax is increased, then rebound to a higher level in the medium term.
  - Temporary consumption decline would reduce tax collections and contribute to a marginally higher deficit, with government debt rising by less than 0.1 percentage point.
  - In the medium- to long-term, fiscal revenue would be higher and government debt lower by about 0.15 percentage point.
- Timing and complementarities:
  - Positive effects are largest in the medium- and long-term and are reached gradually.
  - Timing should consider the position in an economic cycle and other public spending reforms.
  - The current economic recovery with a positive output gap is noted as a good opportunity to consider such a reform.
  - Amplification and mitigation: Positive impact can be amplified and short-term adverse impact minimized when combined with other growth-enhancing structural reforms (reforming state-owned enterprises; enhancing labor market flexibility and labor quality for younger and elder workers; improving product and service markets).

### SME taxation (Annex II) — key points and regime options
- SMEs are diverse; small and micro enterprises constitute between 85–95 percent of business taxpayers but contribute mostly small tax revenue.
- SME taxation should be treated as a special case and coherently include business income taxpayers below the VAT registration threshold.
- Rationale for special SME treatment: preserve employment, increase horizontal and vertical equity, enhance economic efficiency, support tax morale, and improve government accountability and transparency.

Regime options described:
- Indicator-based patent tax regime:
  - Substitutes for income tax and social contributions for micro or sole traders.
  - Fixed fee across activities; simple; no bookkeeping required; regressive; encourages formalization but may hinder growth due to compliance burdens when migrating.
- Presumptive taxation based on indicators:
  - Uses physical indicators or financial information as proxy income indicators.
  - Little bookkeeping; potential complexity and cross-sector incomparability; may create distortions versus general regime.
- Turnover-based SME taxation:
  - Available to firms under the VAT registration threshold.
  - Flat tax of say 3-5 percent on gross receipts in lieu of income taxation.
  - Effective tax rate varies inversely with profit margins; requires simple bookkeeping (record sales).
- Cash-flow based presumptive tax:
  - Single-entry bookkeeping; offsets gross receipts against total expenditures/costs with immediate expensing of capital expenditure.
  - Replaces income tax and achieves equal effective tax rates across sectors.

Tax design and avoidance challenges:
- Presumptive regimes encourage splitting of businesses to benefit from lower effective rates.
- Lower SME regime burdens relative to wage tax can induce conversion of employees into independent contractors.
- Low compliance standards in SME regimes complicate verification of tax facts and provide opportunities to remain in the shadow economy.

*Source: Republic of Slovenia — International Monetary Fund (extracted content).*

### 8.      Tax policy advice for correcting slippage and leakage from the general tax system—

### 8.      Tax policy advice for correcting slippage and leakage from the general tax system—

### VAT registration threshold and SME tax regime
- Use a well-considered VAT registration threshold as the cutoff turnover threshold for the SME tax regime to ensure medium-sized businesses are subject to the general tax regime.
- Clarify the thresholds between micro and small businesses when only turnover is the criterion for differentiation.
- Firms requiring VAT registration (as turnover exceeds the VAT registration threshold) should attract the general income tax.
- Reordering thresholds will facilitate migration into the general regime.

### Treatment of professional services
- Exclude any professional service from the SME regime.
- Exclusion allows for streamlined and synchronized VAT returns, CIT filing, and tax payment obligations.

### Tax administration: audits, filing support, and SME assistance
- Provide special audit and tax filing support by the tax administration to SMEs to shore up trust and tax morale.
- Conduct risk-based tax audits of presumptive taxpayers, addressing abuse by large taxpayers.
- Implement SME assistance and advisory programs focused on improving SMEs bookkeeping standards to encourage compliance.

*Republic of Slovenia — International Monetary Fund*

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_Source: https://www.imf.org/-/media/files/publications/cr/2019/1svnea2019002.pdf_
