Share with your friends

Slovakia: Guidelines for transfer pricing documentation

Slovakia: Guidelines for transfer pricing documentation

The Ministry of Finance of the Slovak Republic issued new guidelines concerning the transfer pricing documentation requirements.


Related content

The new guidelines—no. MF/019153/2018-74 (December 2018)—replaced prior guidelines from 2016, and reflect significant changes with respect to the criteria for determining the types of documentation that taxpayers must maintain as well as the content for each type of documentation.

In general, the transfer pricing documentation requirements in the December 2018 version of the guidelines reflect recommendations of the OECD’s base erosion and profit shifting (BEPS) Action 13.

  • The new version of the transfer pricing documentation guidelines is effective for the tax periods beginning after 31 December 2017.
  • The tax authorities may request documentation for the 2018 tax period only after 1 April 2019.
  • When submitting transfer pricing documentation before 31 June 2019 (i.e., within a transitional period), taxpayers may decide whether to follow the 2016 guidelines or the 2018 guidelines.
  • After 30 June 2019, taxpayers must submit the documentation that comports with the requirements of the 2018 version of the transfer pricing documentation guidelines.

Like the 2016 version of the transfer pricing documentation guidelines, the 2018 version recognizes three types of documentation—simplified, basic, and full-scope. However, the 2018 guidelines reflect significant changes when compared to the 2016 guidelines specifically concerning the criteria for determining the type of documentation that a taxpayer must keep, as well as the content of each type of documentation. For example, the simplified documentation under the 2018 guidelines is now a prescribed form (included as an appendix to the 2018 guidelines).

In addition, the Master file of the full-scope documentation reflects one of the most significant changes to the guidelines and now is more complex. Depending on the type of information requested, preparation of the Master file by Slovak subsidiaries of multinational entities could be very challenging without intensive support from the taxpayer group’s headquarters. Thus, taxpayers need to consider making sure that there is sufficient time for its preparation.

KPMG observation

Taking into account the significant changes in the 2018 version of the transfer pricing documentation guidelines and also considering that taxpayers with related-party transactions will be affected by these rules, careful examination of the new guidelines is warranted in the preparation of transfer pricing documentation. 

Note that the deadline for submitting transfer pricing documentation has not changed—that is, it is due 15 days after a request by the tax authorities.  No extension is allowed.     


Read a February 2019 report prepared by the KPMG member firm in Slovakia

© 2020 Copyright owned by one or more of the KPMG International entities. KPMG International entities provide no services to clients. All rights reserved.

KPMG refers to the global organization or to one or more of the member firms of KPMG International Limited (“KPMG International”), each of which is a separate legal entity. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. For more detail about our structure please visit

Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us


Want to do business with KPMG?


loading image Request for proposal