The new Guidelines on transfer pricing documentation introduce a significant change

The new guidelines introduce changes to the obligation to keep documentation in a simplified scope and modify the definition of the tax period for which the guidelines are first applicable. Other adjustments are primarily aimed at enhancing the clarity and comprehensibility of the text.

New expanded structure of Table I - Transactions with related parties in the tax return

A subtle change in Table I - Transactions with related parties in the corporate income tax return has resulted in a significantly expanded structure. This change affects every taxpayer engaged in transactions with related parties, regardless of the type of documentation they are required to keep. The tax return must now include the exact type of transaction, the name of the counterparty, the country of the counterparty's residence, and the transaction value.

The aim of this change is to reduce the administrative burden for a certain group of taxpayers. Taxpayers who previously prepared simplified documentation can now fulfil this obligation by properly completing the tax return. If the table is not filled out correctly or completely, they will still need to prepare the documentation in simplified scope.

A secondary, yet potentially significant impact is the availability of detailed and structured information on controlled transactions in the new expanded table for all taxpayers. This data can alter the nature of risk analysis and subsequent audits from the tax authority's perspective. It enables automated cross-analyses (such as comparisons with EC Sales Lists/VAT Ledger Statements, withholding tax, financial statements, or Country-by-Country reporting and other public registers). These analyses can help promptly identify deviations from the typical range of independent companies. The tax authority may focus its analytical activities on specific types of transactions (e.g., services, loans) or transactions with entities in particular jurisdictions (e.g., the Netherlands, Cyprus).

The data from Table I of the tax return also opens opportunities for the tax authority to conduct risk analyses not only from a transfer pricing perspective but also concerning other taxes, such as the application of exemptions or reduced withholding tax rates.

This new approach may lead to fewer unpredictable challenges and tax audits for taxpayers, but it also imposes higher demands on the reliability of input data and risk management related to transactions with related parties. We are glad to provide you with practical recommendations.

Types of documentation remain

The Guidelines MF SR 2025 continue to distinguish three types of transfer pricing documentation based on scope: simplified, basic, and full-scope. Content-wise, these documentation types have not undergone significant changes.

When the new guidelines take effect

The new Guidelines of the Ministry of Finance of the Slovak Republic No. MF/012879/2025-724 on determining the content of the transfer pricing documentation according to § 17(7) and § 18(1) of the Income Tax Act (Guidelines MF SR 2025) have been published in the Financial Bulletin. They replace the previous guidelines MF/020061/2022-724.

Guidelines MF SR 2025 will first apply to the preparation of documentation for the tax period in which the last day for filing the tax return falls after December 31, 2025.

This represents a fairly significant change in practice. Previously, earlier versions of the guidelines applied to tax periods beginning on January 1 of the respective year. Companies with a fiscal year ending, for example, in October 2025, will now follow the new rules of Guidelines MF SR 2025 when preparing their documentation.

How to Prepare

Are you unsure whether the new rules will affect your company? A professional consultation can help you properly set up processes, assess risks, and prepare transfer pricing documentation in accordance with the new guidelines. We are happy to review your specific situation and explain what changes in practice and how to prepare for it in advance.