Transfer pricing

The term transfer pricing simply means pricing of various business transactions between related parties in a manner ensuring hidden transfer of profits. Slovak law regulates transfer pricing to a certain extent.

According to the Slovak Income Tax Act, if a foreign party and a Slovak party are related, they are subject to Slovak transfer pricing rules. In such case, transfer pricing documentation is required to be kept by this Slovak related party. A related party means a close party or another party, which is economically, personally, or otherwise interrelated with a foreign party. The threshold for being recognized as economically related party is 25% of direct or indirect share of voting rights or registered capital. For time being, the persons who do not enter into economic relations with foreign related parties are not required to prepare transfer pricing documentation.

If a taxpayer fails to submit the transfer pricing documentation, there are various types of sanctions that could be potentially imposed. Firstly, non-compliance with arm´s length principle may lead to adjusting of tax base of a taxpayer by using of different aids by the tax authorities, which mostly are not in favor of the taxpayer. Furthermore, the taxpayer shall be imposed a fine mainly as a result of failure to submit transfer pricing documentation or non-compliance with arm´s length principle.

What we offer?

  • Analysis of related-party transactions, and an assessment of related risks
  • A functional analysis for the Slovak company, and the choosing of appropriate transfer-pricing methods
  • Preparation of benchmarking studies to support profit margins
  • Preparation of transfer pricing documentation
  • Assistance with obtaining approval from the tax authorities on transfer-pricing methods
  • Assistance with structuring the flow of intra-group transactions to create an effective tax model
  • Assistance in communication with the tax authorities during potential transfer-pricing inspections
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