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Transfer Pricing

Basic Transfer Pricing Documentation

The basic transfer pricing documentation is a slightly more robust document than the one prepared for the shortened transfer pricing documentation. In practice, the most frequent are companies to which foreign companies are affiliated and for this reason, these companies have to prepare basic transfer pricing documentation. The Guideline of the Ministry of Finance of the Slovak Republic defines entities with this obligation as all taxpayers who are not obliged to prepare shortened or complete transfer pricing documentation.

The basic transfer pricing documentation includes:

  • identification and legal form of individual group members, description of the group’s organizational and ownership structure, a general description of the functions performed by the individual members of the group and their foreseeable risks.
  • identification and legal form of the taxpayer, description of its organizational and ownership structure, description of the taxpayer’s business activities and business strategy, identification of the economic sector, business relations and activities of the taxpayer in the economic sector,
  • a general description of the functions carried out by the taxpayer, the assets it uses and its foreseeable risks;
  • a list of inspected transactions, a description of each transaction controlled by the taxpayer, which serve as the identification of the parties of the inspected transaction, the monetary statement of the transaction value and other information about the transaction being inspected (trading conditions and other facts affecting controlled transactions);
  • a description of the taxpayer’s transfer pricing system, including information on the choice, the manner of applying the transfer pricing method(s) and the pricing of controlled transactions;
  • Information about monetary and non-monetary benefits provided on the taxpayer’s behalf to a healthcare provider, its employee or to a healthcare worker from a foreign dependent person, if these recipients are taxpayers with unlimited tax liability in the territory of the Slovak Republic, except for benefits paid for clinical trials.