The Ministry of Finance of the Slovak Republic has published guidance on transfer pricing documentation, along with a new template of the corporate income tax return applicable for 2025. Amendments to CIT return (table I) effectively expand the scope of data reported on related-party transactions and may significantly influence risk analyses and tax audits.
Key change: expanded scope of data disclosed in the tax return.
The new transfer pricing guidance places increased emphasis on reporting information directly within the CIT return. Taxpayers will be required to disclose detailed information on related-party transactions, including:
- the type of transaction,
- the name of the related party,
- the country of its tax residence,
- the transaction value.
The expanded scope enhances reporting transparency and enables tax authorities to conduct more effective risk assessments.
The obligation applies to all taxpayers entering into controlled transactions, regardless of whether they prepare simplified, basic, or full transfer pricing documentation.
Who is affected by new guidance on transfer pricing documentation in Slovakia and when do the changes apply?
Particular attention should be paid by:
- corporate groups conducting intra-group transactions,
- entities with a non-standard financial year,
- businesses transacting with counterparties in other jurisdictions.
The new rules will apply to tax periods for which the filing deadline falls after 31 December 2025, requiring early preparation and adjustment of reporting processes.
In the case of non-standard financial years, the new obligations may arise earlier than anticipated.
How to prepare your organization for the new requirements?
To mitigate tax risk and ensure compliance, taxpayers should consider:
- reviewing related-party transactions,
- verifying the accuracy of transaction classification,
- adapting accounting and reporting systems,
- ensuring consistency of data across tax returns and financial statements,
- conducting training for finance teams,
- assessing tax risk at the group level.
Frequently Asked Questions
- Do the changes apply only to large corporate groups?
No. Any taxpayer engaged in related-party transactions may be affected. - Are companies with a financial year ending in 2025 already subject to the new rules?
Yes. If the filing deadline for the tax return falls after 31 December 2025, the new guidance must be applied. - What should be reviewed carefully in the data?
Consistency in the naming of entities and countries, correct classification of transaction types, alignment of values with statutory records, and completeness of agreements, amendments, and calculation support.
How ASB Group can support your business in regards to new guidance on transfer pricing documentation?
Changes in transfer pricing documentation requirements necessitate a thorough review of transactions and adjustments to reporting processes. ASB’s TAX Team supports businesses in achieving compliance and mitigating tax risks.
Our support includes:
- analysis of documentation and reporting obligations,
- verification of related-party transactions from an arm’s length perspective,
- preparation of benchmarking analyses for intra group transactions using international data bases
- preparation of transfer pricing documentation,
- assistance with reporting and disclosure requirements,
- identification of tax risks and remedial recommendations,
- advisory on transfer pricing policies.
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Source:
MF/012879/2025-724 Usmernenie Ministerstva financií Slovenskej republiky č. MF/012879/2025-724 o určení obsahu dokumentácie podľa § 17 ods. 7 a § 18 ods. 1 zákona č. 595/2003 Z. z. o dani z príjmov v znení neskorších predpisov
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