The Financial Directorate in Slovak Republic has issued a methodological guideline on the application of transfer pricing methods. According to the changes to the OECD Transfer Pricing Guidelines in July 2010, the amendment to the ITA has abolished the hierarchy of transfer pricing methods. Based on price comparison, traditional transactional methods have not been given preference over other methods and it is effect from January 1, 2014.
Approval request of transfer pricing methods must be submitted within a period no lower than 60 days before the starting of the period in which the method requested for approval is to be applied. The requests will be subject to a charge from September 1, 2014: the charge will be 1% of the for unilateral approvals but no less than € 4,000 and no more than € 30,000. The fee will be 2% of for bilateral or multilateral approvals but no less than € 5,000 and no more than € 30,000. Another change concerns the imposition of a compulsion on the taxpayer to present transfer pricing documentation at the request of the tax administrator within 15 days of delivery request.
