Transfer pricing in Slovakia

Transfer pricing in Slovakia at a glance

Regulation Type OECD
Are there specific transfer pricing regulations? Yes
Submission deadline N/A
Submission deadline upon request 15
Annual update required Yes
Official language requirements Slovak
Potential impact of penalties N/A

 

Slovakian tax law

Rules for transfer pricing in Slovakia are based upon:

  • Corporate Income Tax sections 2, 17 and 18
  • Act on International Assistance and Cooperation by Tax Administrators

OECD

Rules for transfer pricing in Slovakia generally follows the OECD Transfer Pricing Guidelines. The guidelines, however, have not been incorporated in the Slovakian Tax laws.

Methods

Accepted methods

Accepted methods are:

  • the comparable uncontrolled price method
  • the resale price method
  • the cost plus method
  • the profit split method
  • the transactional net margin method

Priority of methods

Rules for transfer pricing in Slovakia do not prescribe a priority of methods.

Documentation requirements

Information that should be included in the documentation:

  • Information about each transaction or homogenous group of transactions
  • Information about the company and about the group as whole
  • The local documentation should also include analysis of the comparability of the transactions

Language                                                   

Officially documentation should be provided for in the Slovak language. However, upon request it may be decided to provide the documentation in a different language.

Requirements to prepare documentation annually

Documentation should be prepared upfront for every period of taxation.

Submission deadline upon request by tax authorities

Upon request by the tax authorities a taxpayer has 15 days to submit the documentation.

Advance Pricing Agreements

General

Advance Pricing Agreements (APA’s) are available in Slovakia. However, APA’s only apply for the transfer pricing method and not for the mark-up.

Terms

Rules for transfer pricing in Slovakia decide that the maximum term for an APA to be agreed upon is five years.

Penalties

Rules for transfer pricing in Slovakia do not provide for specific transfer pricing penalties.

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