Transfer pricing is one of the most frequently audited areas of tax administration. Incorrectly set prices between related parties can lead to additional tax assessments, penalties, or even criminal liability.
Our goal in transfer pricing advisory is to eliminate or at least reduce the tax risks associated with transactions between related parties and to optimise the tax obligations arising from these transactions.
Our Services
Tax Documentation
Preparation of legally required documentation, including comparability analysis from publicly accepted databases.
Tax Risk Analysis
Identification and assessment of tax risks associated with transactions with related parties.
Permanent Establishment
Profit attribution to a permanent establishment of a foreign enterprise operating in Slovakia.
TP Policies & Guidelines
Setting up internal transfer pricing policies and guidelines for intercompany accounting between related parties.
APA & MAP
Assistance with filing applications for advance pricing agreements and mutual agreement procedures.
Cost Sharing Agreements
Analysis and preparation of cost-sharing agreements between related entities within a group.
Want to better understand transfer pricing?
Contact our experts or download the Transfer Pricing Guidelines prepared by our expert Mirka Kusová.
Get free access to the Transfer Pricing Guidelines
Our Transfer Pricing Guidelines will help you navigate current requirements. Leave us your contact details and we will send it directly to your email.
Overview of key principles
Practical table with specific documentation types
Description of criteria applicable under Slovak legislation
Precise definition of documentation required to be submitted to the authorities
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Frequently Asked Questions
01 Who is subject to the documentation obligation?
The transfer pricing documentation obligation applies to all related parties (connected entities) that carry out controlled transactions. The scope of documentation depends on the level of turnover and transaction values — a distinction is made between abbreviated and full documentation.
02 What are the penalties for missing or incorrect documentation?
In the absence of or incomplete documentation, the tax authority may impose a fine of up to EUR 10,000 per audited year, with the total penalty potentially being significantly higher when additional tax assessments and late payment interest are taken into account.
03 How long does it take to prepare TP documentation?
Standard preparation of TP documentation takes 4 to 8 weeks depending on the complexity of the transactions and the availability of materials from the client. For urgent cases, we can expedite the process.
04 What is an APA and when is it worth applying for one?
An Advance Pricing Agreement (APA) is an agreement with the tax authority on a pre-approved transaction pricing method. It is worthwhile for recurring high-value transactions where you want certainty and wish to eliminate the risk of future tax audits.
05 What is MAP and how does it work?
The Mutual Agreement Procedure (MAP) is a mechanism for resolving disputes between the tax authorities of two countries. It is used in situations where double taxation arises as a result of a transfer pricing adjustment made by one of the parties.
06 Does the obligation also apply to small companies?
Yes, the documentation obligation also applies to smaller companies if they carry out transactions with related parties. Micro and small enterprises are subject to a simplified abbreviated documentation regime, but every entity must maintain basic records.
Why Grant Thornton?
35+
years of experience
Longstanding practice in transfer pricing on both the Slovak and international markets.
130+
countries in the Grant Thornton network
Global reach with local expertise — ideal for international groups operating in Slovakia.
100%
local knowledge of legislation
Our team monitors changes in Slovak tax legislation and OECD guidelines and translates them into practice.
