Transfer pricing in Slovenia at a glance
|Are there specific transfer pricing regulations?||Yes|
|Submission deadline||Together with corporate tax return|
|Submission deadline upon request||30 to 90 days|
|Annual update required||Yes|
|Official language requirements||Slovenian|
|Potential impact of penalties||EUR 30,000|
Slovenian tax law
Rules for transfer pricing in Slovenia are based upon:
- Corporate Income Tax Act articles 16, 17, 18 and 19
- Tax Procedures Act articles 382, 397 and 398
Rules for transfer pricing in Slovenia generally follow the OECD Transfer Pricing Guidelines.
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 Slovenia suggest that the most appropriate method should be used. Keeping that in mind, the traditional methods are preferred over the transactional methods.
Information that should be included in the documentation:
- A description of the taxable person
- A description of the global organisational structure of the group
- An explanation of the type of connections between the companies in the group
- An explanation of the method used in the determination of transfer prices
- A description of the business activities and business strategies (including any general economic and other factors, an assessment of the competitive environment, etc.)
- A description of transactions between affiliated persons
- A functional analysis determining the main functions performed and risks undertaken by the taxpayer, and outlining which adjustments may need to be made in relation to comparable situations
- A description of any comparable search performed
- A description of business strategies
- A description of goods/services transferred/rendered
- A description of the method applied for establishing the arm’s length price
- Any other information that might be relevant from the transfer pricing perspective should also be included in the documentation
Documentation should generally be provided for in Slovenian. However, sometimes English is accepted as well.
Requirements to prepare documentation annually
Documentation should be prepared together with the annual tax return.
Submission deadline upon request by tax authorities
Upon request of the tax authorities, documentation should be submitted to the tax authorities between 30 and 90 days after a request has been made.
Advance Pricing Agreements
Rules for transfer pricing in Slovenia do not provide for an option to obtain for an Advance Pricing Agreement.
Rules for transfer pricing in Slovenia provide for regulations that could impose a fine up to EUR 30,000 in case a taxpayer fails to comply with transfer pricing documentation.