Transfer Pricing

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Any company in Slovakia engaged in foreign intra-group transactions must be able to support prices agreed between related parties in order to meet the condition of arms-length price. Our dedicated team can design a transfer pricing strategy customised to fit your business requirements. We use industry-specific benchmarking to determine an effective arms-length price for goods and services. This also allows you to adjust your transfer pricing to optimise your overall profitability. We also provide you with all the documentation required to comply with OECD guidelines.

  • Review and assessment of the client’s transactions between related parties and evaluation of risks.
  • Review and preparing the group transfer pricing policies including the applicable documentation that should be available in case of tax inspection. The documentation mainly includes agreement between the Slovak and foreign related party, calculation of the allocation key, and evidence that the price charged between related parties does not significantly exceed the arm’s length price.
  • Analysing the functions of the Slovak company, choosing the most appropriate method for determining the arm’s length price and preparing the benchmarking study to support the method.
  • Assisting with obtaining the approval from tax authorities on the method of determining the tax base of foreign company’s permanent establishment in Slovakia.
  • Advising the client on transformation of business structure to a more tax effective model.
  • Assistance in any negotiations you may have with the tax authorities.