Slovak Republic - New transfer pricing documentation guidance published

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Slovak Republic - New TP documentation guidance published
The Ministry of Finance published updated guidance on the content of TP documentation on 6 February 2019. The scope of obligation to submit TP documentation depends on the category of taxpayer. It can be: (1) the full TP documentation, (2) the basic TP documentation and (3) the simplified TP documentation.

The full TP documentation consists of a Master File and a Local File and is required for cross-border transactions of taxpayers that maintain accounting in accordance with IFRS Standards, or for significant cross-border transactions, where the value of the transaction or group of interrelated transactions exceeds EUR 10 million or where the counterparty is a resident of a non-treaty jurisdiction, and in the case of requests for obtaining an APA and initiating a MAP.

The basic TP documentation consists of a simplified Master File and Local File. The basic TP documentation is required for taxpayers whose revenues exceed EUR 8 million or the value of the transaction or group of transactions in a year exceeds EUR 1 million.

The simplified TP documentation is replaced by a specific overview return. The overview return contains a summary of the transactions with related parties. This simplified set of TP documentation should be submitted when the full or basic TP documentation is not required.

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