Transfer pricing in Slovakia at a glance
|Are there specific transfer pricing regulations?||Yes|
|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
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.
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.
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
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
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.
Rules for transfer pricing in Slovakia decide that the maximum term for an APA to be agreed upon is five years.
Rules for transfer pricing in Slovakia do not provide for specific transfer pricing penalties.