Transfer Pricing Legislation in the Slovak Republic

It’s no secret that more and more countries are formalizing transfer pricing legislation and, in many cases, taking nods from the OECD’s transfer pricing guidelines.

One of the latest to follow suit: The Slovak Republic. The Ministry of Finance has proposed amendments to the Income Tax Act and the Act on Tax Administration including motions to limit excess interest deduction, change the income tax registration process, and also to modify—and clarify—existing transfer pricing rules.

What the Amendments Include

• Clarifying the definition of related-party transactions
• Adding to rules that determine the tax base of permanent establishments
• Further explaining the rules that allow for transfer pricing adjustments

The amendments officially refer to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations in applying the transfer pricing rules.

The updated transfer pricing laws go into effect on January 1, 2023.