The Ministry of Finance of the Slovak Republic issued new guidelines no. MF/019153/2018-724 (MF SR Guidelines 2018) on content of the transfer pricing (TP) documentation was issued in December 2018 replacing the Guidelines no. MF/014283/2016-724 (MF SR Guidelines 2016).
The transfer pricing documentation requirements in the December 2018 version is in accordance with the recommendations of the OECD’s base erosion and profit shifting (BEPS) Action 13. According to the new Guidelines, there are 3 types of documentation such as simplified, basic, and full-scope. Now the tax payers are obliged to keep the complete documentation for cross-border transactions or a group of transactions which may be combined and exceed the amount of EUR 10 million.
MF SR Guidelines 2018 are effective for the tax periods beginning after December 31, 2017. The Tax Authorities may request the documentation for 2018 tax period only after April 1, 2019. However, when submitting the documentation before June 30, 2019, i.e. within the transitional period, the taxpayer may decide whether to follow the MF SR Guidelines 2016 or the MF SR Guidelines 2018. After June 30, 2019, the taxpayer must submit the documentation in line with the MF SR Guidelines 2018.
