The new guidelines supersede the transfer pricing guidelines of 2022 and will apply to documentation for any tax period where the tax return filing deadline is after 31 December 2025.

Regfollower Desk

The Slovak Republic’s Ministry of Finance has released updated guidelines on transfer pricing documentation (MF/012879/2025-724) and introduced a new 2025 corporate income tax return form, which includes a redesigned “Table I – Transactions with related parties.”

The purpose of this mandate is to establish rules for documenting the method used to determine prices and conditions in controlled transactions—those occurring between related parties—to demonstrate alignment with the arm’s length principle.

The revised rules now require reporting detailed transaction data, including the transaction type, the counterparty’s name and country of residence, and the transaction amount.

The full documentation must include extensive group information, such as organisational structure, supply chains, financing arrangements, intangibles, and consolidated financial statements, along with proof that pricing complies with the arm’s-length principle.

The document specifies three tiers of required documentation—complete, basic, and shortened, each with distinct scopes. It outlines when taxpayers must prepare each type based on factors such as transaction value, cross-border status, and taxpayer revenue.

Full documentation

The requirement for full documentation signifies the highest level of scrutiny and reporting. This comprehensive set of information is mandatory in several significant scenarios:

  • High-value cross-border transactions: Required for cross-border controlled transactions, or groups thereof, if the value for the tax period exceeds EUR 10,000,000.
  • IFRS reporting and significance: Required for significant cross-border transactions conducted by taxpayers who report their financial results using International Financial Reporting Standards (IFRS).
  • Non-cooperating jurisdictions: Applicable to significant cross-border transactions involving an associated person who is a taxpayer of a non-cooperating state.

Basic documentation

Basic documentation is required for cross-border transactions when full documentation is not required. The thresholds for this requirement include:

  • Transaction value threshold: Cross-border controlled transactions, or groups thereof, where the value for the tax period exceeds EUR 1 million.
  • Revenue threshold: Significant cross-border transactions conducted by a taxpayer whose total annual revenues from economic and financial activity exceeded EUR 8 million for the relevant tax period.
  • Domestic transactions with tax relief: Significant domestic controlled transactions where the taxpayer claims tax relief during the tax period.
  • Non-cooperating jurisdictions: Required for cross-border transactions involving associated persons who are taxpayers of a non-cooperating state.

Shortened documentation

If a taxpayer is not obligated to prepare Full or Basic documentation, the legal requirement to maintain documentation is generally satisfied by submitting a correctly completed income tax return for the period, including the section relating to associated persons. However, if the taxpayer fails to meet this requirement, they must then prepare Shortened Documentation for significant controlled transactions.

These rules apply for the first time to documentation prepared for tax periods where the deadline for filing the tax return falls no earlier than 31 December 2025.

This guidance, numbered MF/012879/2025-724, is issued to ensure a uniform procedure for documenting prices and conditions in significant controlled transactions under the Income Tax Act. This directive, which supersedes the previous 2022 guidelines (MF/020061/2022-724), is based on the Corporate Income Tax Act.