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Slovakia: Guidelines on transfer pricing documentation for 2023

The Ministry of Finance released guidelines on the content of transfer pricing documentation for 2023.

April 30, 2024

The Ministry of Finance released guidelines (MF/020061/2022-724) on the content of transfer pricing documentation for 2023.

The guidelines provide for three types of transfer pricing documentation:

  • Full-scope documentation: Master file and Local file (in which taxpayer must demonstrate that the applied transfer prices are in line with the market conditions)
  • Basic documentation: Master file (but not as complex and detailed as full-scope) and Local file (but not mandatory to demonstrate the market setting of transfer prices)
  • Simplified documentation: Information according to the structured form

Read an April 2024 report prepared by the KPMG member firm in Slovakia

Transfer pricing documentation is due within 15 days of receipt of a request from the tax authority or financial directorate, and such a request may be sent no earlier than the first day following the tax return filing due date, which for calendar year taxpayers is 2 April 2024. Thus, a request to submit transfer pricing documentation for the 2023 may be sent as early as 3 April 2024.

Read an April 2024 report prepared by the KPMG member firm in Slovakia

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