Transfer Pricing

Shortened Transfer Pricing Documentation

Shortened transfer pricing documentation is the briefest and administratively simplest form of transfer pricing documentation.

Taxpayers who should prepare shortened transfer pricing documentation within the meaning of the Ministry of Finance of the Slovak Republic Guideline are:

  • natural persons;
  • the micro accounting entities as defined in § 2 Art. 6, 10 and 11 of Act no. 431/2002 Coll. on Accounting;
  • taxable persons carrying out domestic controlled transactions (i.e. transactions with dependent persons who are taxpayers with unlimited tax liability, excluding transactions in relation to the permanent establishments of those taxpayers located abroad); if these taxpayers also perform foreign controlled transactions (i.e. transactions with dependent taxpayers who are taxable persons with limited tax liability and, where applicable, transactions with permanent establishments of taxpayers with unlimited tax liability located abroad), this rule applies only to the part of the documentation in relation to domestic controlled transactions;
  • taxable persons as defined in the Act No. 431/2002 Coll. on Accounting (e.g. legal persons controlled by the state under special regulations, state funds, organizations funded or receiving contributions from the state budget, entities established by a municipality or a higher territorial unit), in the range of transactions carried out with other persons as defined in Act No. 431/2002 Coll. on Accounting.

The shortened transfer pricing documentation contains the following information within the meaning of the Ministry of Finance of the Slovak Republic Guideline:

  • identification and legal form of individual group members, description of the group’s organizational and ownership structure;
  • a list of controlled transactions;
  • a description of the individual taxpayer’s controlled transactions that includes the identification of the parties to the transaction being inspected, the monetary statement of the transaction value and other information about the controlled transaction (e.g. business conditions and other facts affecting controlled transactions);
  • information on the monetary and non-monetary benefits provided on taxpayer’s behalf to the healthcare provider (the Act No. 578/2004 Coll., on healthcare providers, healthcare workers, health organizations, and amendments to certain acts, as amended, or its employee or to a healthcare worker from a foreign dependent person, if these recipients are taxpayers with unlimited tax liability in the territory of the Slovak Republic, other than those benefits paid for clinical trial (the Act No. 362/2011 Coll., on Medical Products and Medical Devices and on amendments to certain laws as amended).