Meet our Transfer Pricing advisory team from Slovakia: Striking a balance between numbers and rules | People of Accace 

In our #PeopleOfAccace series, we take you behind the scenes at Accace through interviews. You’ll learn how new services and solutions are developed, who has been with Accace the longest and the various positions they have held over the years. But most importantly, you’ll get to know our amazing people. In the current interview, we focus on the Transfer Pricing advisory team from Slovakia. 

What should we understand by the term transfer pricing? How does it relate to regular business activities? 

Transfer pricing involves setting prices for transactions between related companies within a group. It means determining prices for goods, services, loans, or licenses in line with market conditions – in other words, the prices that would be agreed upon between independent companies. 

Properly setting transfer prices is important not only for companies but also for tax authorities. It helps prevent artificial shifting of profits between countries to reduce tax liabilities. Therefore, companies subject to these rules must maintain documentation detailing transactions, pricing methods, and comparisons with independent transactions. 

This documentation must be regularly updated and made available for review by tax authorities. Properly set transfer pricing helps minimize tax risks and ensure compliance with legislation. 

How does your daily teamwork in addressing client needs, and with which other teams do you most frequently collaborate? 

Collaboration within the team is highly dynamic; we regularly communicate, exchange information, solve problems, and adjust strategies based on changing client requirements. It is also essential   that our team monitors current changes in tax legislation affecting transfer pricing and adapts client documentation accordingly. 

We work on long-term projects, coordinating tasks and sharing information regularly to  effectively address client needs meet client needs effectively. Regular team meetings allow us to track progress, address challenges, and adjust strategies based on evolving requirements. We closely collaborate with the tax team, sharing information about the connection between transfer prices and their impact on clients’ tax returns. We also communicate with the accounting department, which can provide insights into clients and their issues, especially  when working with shared clients, helping us better understand the company’s overall functioning. 

A significant part of our work involves preparing transfer pricing documentation for our clients. This is a legislative requirement for companies conducting intra-group transactions. The scope of transfer pricing documentation can be compared to a thesis, sometimes even a dissertation. Its goal is to justify that the company has correctly set transfer prices. Transfer pricing is not an exact science; each company is unique, and therefore, the documentation process cannot be standardized. Some transactions are very complex, and legislation does not always provide clear rules on how to set transfer prices correctly. Therefore, our team often has to  work closely together to find the best way to set and justify transfer pricing policies that satisfy both client needs and tax authority requirements. 

What typical problems or situations do companies come to you with? Can you mention an interesting or unusual case? 

Companies come to us with questions about setting transfer prices in compliance with current legislation, preparing mandatory documentation, or defending pricing before tax authorities. A common challenge is correctly setting pricing models for new business relationships, restructurings, or expansions into foreign markets. An interesting case involved a client who needed to justify differences in margins between different countries, considering not only economic factors but also regulatory constraints and local market specifics. Such situations require detailed analysis and individual solutions to ensure compliance with regulations and optimize the client’s business model. 

The biggest challenges are always more complex transactions, such as financial transactions, transfers of intangible assets, sales of goods traded on exchanges, etc. But the more challenging the case, the more interesting it is. 

What do you find most interesting about this work? 

Lea Balogová: What I enjoy most about working in transfer pricing is the diversity of clients and industries I come into contact with. Each project is unique and brings new challenges, whether it’s international corporations, family businesses, or fast-growing companies. This diversity requires an individual approach and in-depth analysis, making the work dynamic. I am also motivated by the opportunity to collaborate with experts from various fields during the preparation of transfer documentation, where we not only meet accountants and tax advisors but also people from practice who deal with the technical side of business. They can explain the functioning of the company, processes, and products, helping me better understand pricing and how different industries operate. 

Zdenka Karak: The fact that transfer pricing is not an exact science has its advantages. In transfer pricing, there is no clear distinction between black and white. Therefore, one must be very creative and find the right solution for each new project. And that is what I find most interesting. 

Martin Hašan: As Zdenka mentioned, transfer pricing is not an exact science, and what I enjoy most is the dynamism and diversity this work brings. I am very interested in multinational groups that are diverse and can constantly adapt to different markets, trends, and cultures. I am also drawn to working with numbers, which involves cost calculations and profitability analyses, where transfer pricing connects accounting, taxes, and controlling. This work also includes preparing economic analyses and strategic documents, making it even more varied. Solving complex problems – finding balanced solutions that meet legislative requirements while supporting company efficiency – I find particularly interesting. This work fulfills me because it combines technical knowledge with creativity and allows me to learn and develop in an ever-changing environment. 

Michal Lovas: Transfer pricing provides the opportunity to work with various industries and types of transactions, making it a diverse and dynamic field. This constantly offers room to learn new things and gain new expertise across multiple industries. 

How is transfer pricing evolving today? Are you facing new trends, challenges, or legislative changes? 

Lea Balogová: Transfer pricing is constantly evolving in response to changing regulatory requirements, international standards, and increasing emphasis on transparency. The growing digitalization also means that tax authorities have access to a broader range of data andemploy advanced analytical tools to identify potentially risky transactions. Companies therefore face higher demands for thorough documentation and defensibility of their transfer prices. Additionally, the increasing globalization and digitalization of business bring new collaboration models that require adapting existing transfer pricing strategies. 

Zdenka Karak: Transfer pricing is part of international tax rules, so besides domestic legislation, we must also monitor international legislation, such as the OECD Transfer Pricing Guidelines, which are considered our main reference. Transfer pricing has been evolving very dynamically recently, transactions are becoming more sophisticated, and the number of tax audits focused on transfer pricing is increasing. Therefore, we must constantly monitor all new trends. Similarly, legislative changes in transfer pricing have been very significant since 2023. 

Martin Hašan: Besides changes in trends and legislation affecting transfer pricing, I would like to add that we are also striving to adapt in the area of using modern technologies. We actively implement tools like artificial intelligence, which help us work more efficiently, accurately, and quickly. These technologies allow us not only to analyze complex data but also to better identify risks and provide clients with more robust services. We constantly strive to improve our processes and bring innovative solutions to keep up with the dynamic demands of this field. 

Michal Lovas: Transfer pricing today faces various changes, trends, and challenges associated with rapid economic, technological, and legislative changes. These factors shape how companies approach pricing their international transactions and adapt their strategies to avoid tax risks and ensure compliance with new regulations. 

Tell us something from your personal life. How do you spend your free time, and what helps you maintain a balance between work and personal life? 

Lea Balogová: In my free time, I enjoy relaxing with a good book, movie, or music, which helps me unwind and recharge. I also value time spent with family and friends, which brings balance to my work and personal life. 

I believe that maintaining this balance is also contributed by the ability to organize time effectively, separate work matters from personal life, and regularly take moments for regeneration and personal development. 

Zdenka Karak: I am the type of person who can’t sit still. So, when I get home, I start “housekeeping,” which I enjoy very much, but my biggest relaxation is arranging flower boxes. I come from the region near the Low Tatras, so in my free time, I am always drawn to the mountains and nature. All these activities help me maintain a balance between work and personal life. 

Martin Hašan: When I have free time, I like to watch a good movie or series; it’s an ideal way for me to unwind after work. However, my family and I often go on easy hikes, as we have beautiful nature around us that always recharges us. I also love history, so we often visit castles, chateaux, or various museums. These things help me relax and maintain a healthy balance in my life. 

Michal Lovas: Outside of work, I try to lead an active lifestyle. I spend most of my free time playing sports. I have been playing tennis actively for 16 years. When I was younger, I played competitively. Additionally, I run or go to the gym. Sports have taught me many values and skills that are valuable not only in sports but can also be applied to work life. One of the most important things I have learned is discipline. Training and following a regimen help develop self-discipline and the ability to approach various tasks responsibly in both personal and work life. Regular physical activity also helps me manage stress and pressure, which is important both in competition and when dealing with challenging situations. Sports have also given me greater endurance and resilience, allowing me to better face obstacles and setbacks, and to bounce back and keep going.