Abstract:

In order to prevent a profit transfer to countries with lower tax burdens and through more frequent tax controls, transfer prices are becoming very problematic issues, especially in the tax area. There has been widespread harmonization internationally, mainly thanks to OECD organization that have issued a number of key guidelines. The national transfer pricing regulation in the Slovak Republic is not as extensive as the regulation at the international level and that is why most of the information is drawn from the guidlines issued by the OECD. In December 2018, the Slovak transfer pricing legislation was amended by new Guidance no. MF/019153/2018-724, which brings a number of significant changes, tightening of obligations for some taxpayers as well as some simplifications. The new guideline tightens the obligation of transfer pricing documentation in a more complex form for transactions where a simple form has been up to now sufficient. The selected transactions, which have so far been subject to an abbreviated form of documentation, are required to have full or basic documentation. New stricter criteria for determining the scope of documentation are also being introduced. And the most significant simplification is omission of transfer pricing documentation for some dependents.