Global

Details

  • Service: Tax, Global Transfer Pricing Services, Global Compliance Management Services, International Tax
  • Type: Regulatory update
  • Date: 4/4/2014

Slovakia - Transfer pricing methodology guidance 

April 4: The Slovak Financial Directorate issued a “methodical guideline” concerning transfer pricing methods.

The Slovak transfer pricing methodology guidance:


  • Describes in detail those transfer pricing methods that are based on a comparison of prices (e.g., traditional transaction method) and those methods that are based on comparing profits (e.g., transactional profit method)
  • Explains certain key terminology and when to use a method(s)
  • States that it is not necessary to prove that the use of certain methods was not appropriate under certain circumstances or conditions, but that it may be sufficient, if based on an analysis of comparability factors, to state that inappropriate methods were excluded

The transfer pricing method selected and used must be “proved” to the tax authorities and the transfer pricing documentation must contain the taxpayer’s reasoning for why a transfer pricing method was chosen.


The Slovak guideline stipulates that, in addition, the substance and use of transfer pricing methods selected by taxpayers are also to follow the OECD transfer pricing guidelines.


Read a March 2014 report [PDF 152 KB] prepared by the KPMG member firm in Slovakia: Tax Alert: Amendments to the Slovak legislation and other topics



Contact a tax professional with KPMG's Global Transfer Pricing Services.




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