Transfer Pricing: key changes for 2025 and beyond

1. New Slovak MoF guidance on transfer pricing documentation 

The Ministry of Finance has issued new guidance on the content of transfer pricing documentation (No. MF/012879/2025-724), replacing the guidance effective since 2023 (No. MF/020061/2022-724).

The new guidance will apply to documentation for tax periods with filing deadlines on or after 31 December 2025. In practice, this will affect the 2025 tax period (filed in 2026).

2. Key changes 

Although the new guidance retains the documentation tiers (full, basic and simplified) and the main thresholds defining the scope of documentation, it introduces a number of important clarifications.  

• Aggregation of transactions: The guidance clarifies when controlled transactions may be aggregated into a single group. The definition of a group of controlled transactions states that multiple controlled transactions may belong to a single group: if they are of the same type and concluded under comparable conditions, if they are closely connected or conditional with one another, or if they are comparable in functions performed, risks assumed, and assets used.
  
  Transactions with different counterparties may also be aggregated in this way. This gives taxpayers greater certainty when grouping transactions where such an approach provides a more reliable picture of the pricing methods used. Any aggregation must be properly substantiated in the documentation, as confirmed by the Kosice Administrative Court in 2024 (see our October 2024 newsletter).

• Change to simplified documentation: Previously, if neither full nor basic documentation was maintained, simplified documentation was required for material-controlled transactions and certain situations (e.g. reporting a tax loss, offsetting a loss or applying a particular tax rate).
  
  From 2025, the rule has been simplified: if the taxpayer does not fall within the scope of full or basic documentation, a duly completed tax return will suffice; if this cannot be done (e.g. due to a limited number of lines in the tax return form), the taxpayer must maintain simplified documentation in the structure shown in the annex to the guidance. This will mean fewer cases where simplified documentation will be mandatory and places a stronger emphasis on accurate disclosure of transactions in the submitted tax return.

3. What’s new in the tax return – Table I

The scope of information on related‑party transactions that must be reported in the tax return in Table I has also been changed. This table is mandatory for all taxpayers that enter into controlled transactions with related parties.

The new corporate income tax return form will be used for tax returns with filing deadlines on or after 31 December 2025, i.e. affecting the 2025 tax period.

In the new form, all significant controlled transactions must be reported in Table I (with a value exceeding EUR 10,000, or principal exceeding EUR 50,000 for financial transactions), regardless of the type of transfer pricing documentation maintained. The following detailed information will be required:

• Name of the related party (business name, or first name and surname),
• Tax residence country code of the related party (counterparty to the controlled transaction),
• Type of transaction code from a new list of 34 types of transactions, and
• Volume of transaction and its impact on profit or the tax base: in the relevant tax period and in future tax periods (e.g. purchase of depreciable tangible assets is reported at acquisition cost in the year of purchase).

Note: Table I is limited to 99 rows. If this is not sufficient, omit the lowest‑value transactions from the table and include them in simplified documentation.

Previously, the tax return did not have to state the specific related party, or its jurisdiction. Transactions were reported by type in aggregate amounts for the tax period. The new form, with the specific counterparty and residence details introduces substantially greater reporting granularity.

Summary and recommendations

The most significant change is that the focus of transparency for controlled transactions is shifted to the tax return. In many cases, this should eliminate the obligation to maintain simplified documentation, provided all transactions are reported accurately and in detail in the tax return.

The tax return is becoming the primary tool for reviewing transfer pricing and will become far more detailed, which the tax authority can then use to better identify high‑risk transactions.

We recommend the following for PwC clients:

• Review your internal data collection processes and existing systems to ensure efficient preparation of the information for the new Table I.
• Prepare for detailed reporting by maintaining comprehensive records of all material transactions, including counterparty details (name, tax residence) and the precise impact on profit or the tax base.
• Optimize your documentation approach by using the new options for transaction aggregation and materiality criteria in line with the latest guidance.
• Consult our PwC experts, who will assist you with impact assessments, implementation of the new requirements and legislative compliance to minimize tax risks.