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International Tax News & Updates

Slovak Republic - New transfer pricing documentation guidance published

3/7/2019

 

Local tax news

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.

If these subjects are something which you find interesting and would like to discuss further we are happy to be at your service. Contact us at [email protected].

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