Transfer pricing documentation
From 1 January 2009 foreign related parties are obliged
to maintain transfer pricing documentation.
The Ministry of Finance of the Slovak Republic is now preparing a Decree
which will specify details concerning the content and rules for the preparation
of that documentation. The content of transfer pricing documentation corresponds
in its main principles with the recommendation of the EU regarding the
transfer pricing documentation.
A foreign related party will be obliged to keep records on transfer pricing documentation for the respective taxable period jointly for the whole group of related parties so called Masterfile and for specific foreign related party, specific documentation.
The Masterfile should contain the following items for example: a general description of the business and business strategy, flows of transactions, invoice flows etc.
Specific (country) documentation should contain the following items: a detailed description of the business and business strategy, including changes in the business strategy compared to the previous tax year, flows of transactions (tangible and intangible assets, services, financial) etc.
The tax payer will be obliged to submit the documentation to the tax authority, when the tax payer wishes to apply for a decision on the approval of the transfer pricing method.
Please do not hesitate to contact us if you have any questions regarding the above. We will be happy to help you with preparing the transfer pricing documentation.