Slovak Republic’s Ministry of Finance has issued guidelines (MF/020061/2022-724) outlining the requirements for transfer pricing documentation for 2023.
These guidelines categorise transfer pricing documentation into three types:
Full-scope documentation
Full-scope documentation requires a Master file and a Local file. Taxpayers must demonstrate that their transfer pricing practices are aligned with market conditions.
Basic documentation
Basic documentation does not require the Master file to be as detailed as full-scope. Furthermore, it is not mandatory for the Local file to be in line with market transfer prices.
Simplified documentation
Simplified documentation consists of information provided in a structured form.
Transfer pricing documentation must be submitted within 15 days after being requested by the tax authority or the financial directorate. Such requests may be made after the tax return filing deadline, which is 2 April 2024 ( for taxpayer calendar year). Therefore, a request for submitting transfer pricing documentation for 2023 can be made on 3 April 2024.