The Ministry of Finance of the Slovak Republic has issued new Guidance on the content of transfer pricing documentation, which replaces the previous guidance.
The purpose of the new Guidance is to define the content requirements for transfer pricing documentation and to amend certain procedures related to its preparation and maintenance. While the basic structure of the documentation remains unchanged, the new Guidance introduces several significant practical changes.

Types of documentation remain the same, but the preparation of the simplified version changes

The new Guidance continues to distinguish between three types of documentation — Full, Basic, and Simplified.
Although the substantive content of these documentation types remains essentially the same, the procedure for preparing the simplified documentation has changed.

Under the new rules, taxpayers required to maintain transfer pricing documentation in the simplified scope will no longer need to complete a separate annex to the Guidance. Instead, it will be sufficient to correctly complete Table I in the Corporate Income Tax Return (CIT Return).
However, if the table is not completed fully or accurately, the taxpayer will still be required to prepare the simplified documentation in full — i.e. to complete the annex to the Guidance.

New and expanded table I – controlled transactions

The most visible change is the new structure of Table I – Controlled Transactions in the CIT return.
For each controlled transaction with a related party, taxpayers will now be required to provide the exact type of transaction, the name of the counterparty, the country of the counterparty’s registered seat, and the transaction value.

The aim of this expansion is to reduce the administrative burden for a certain group of taxpayers while at the same time improving data transparency and accessibility for the Financial Administration.
The tax authorities will be able to use the newly structured data for risk analyses, automated comparisons, and more targeted tax audits.

For companies, however, this will certainly mean the need to keep more detailed records of all controlled transactions already for the purposes of completing the CIT return.

Effective date of the new guidance

The Guidance of the Ministry of Finance of the Slovak Republic for 2025 will first apply to the preparation of transfer pricing documentation for the tax period for which the filing deadline for the tax return falls after 31 December 2025.

This means that companies with a financial year ending, for example, in October 2025 will already be required to follow the new rules.

Zdenka Karak

Senior Transfer Pricing Specialist | Accace Slovakia

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