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Submission of a transfer pricing documentation for 2023

The Tax Authorities may request the transfer documentation for the year 2023 one day after the tax return filing deadline.

According to the Income Tax Act, the taxpayer shall submit the transfer pricing documentation within 15 days from delivery of the tax administration’s or financial directorate’s request, while such request may be sent no earlier than on the first day following expiry of the period for tax return filing.1

If the tax period is a calendar year, taxpayers are required to file a tax return no later than 2 April 2024. The request to submit the transfer pricing documentation for the year 2023 may therefore be sent as early as 3 April 2024.

The new Guidelines of the Slovak Ministry of Finance, as well as the amendment to the Income Tax Act, brought several significant changes in transfer pricing valid from 2023. The individual changes were specifically addressed in our previous articles.

Please feel free to contact our experts before the Tax Authorities request your transfer pricing documentation. We will be glad to help you and look into your transactions with related parties.


1 Article 18(11) of the Slovak Act No. 595/2003 Coll. on Income Tax, as amended.

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