Ing. Viktória Horáčiková
Tax Advisor
In the area of transfer pricing, a fundamental change in documentation obligations will take effect in 2025. The new Guideline of the Ministry of Finance of the Slovak Republic No. MF/012879/2025-724 changes the existing approach to reporting controlled transactions between related parties. The key change is the practical elimination of the obligation for most taxpayers to prepare a separate simplified transfer pricing documentation, which is now replaced by the requirement to accurately and comprehensively complete Table I directly in the corporate income tax return.
Situation Until 2024: Documentation as a Separate Document
Under the rules applicable until the end of 2024, or for tax periods beginning after 31 December 2022, transfer pricing documentation was divided into three levels: full, basic and simplified. The scope of documentation required depended on whether the taxpayer met the criteria set out by law and by the relevant guideline.
Simplified transfer pricing documentation applied to taxpayers who did not meet the conditions for full or basic documentation but were subject to certain tax circumstances. These included cases where the taxpayer reported a tax loss, applied a tax loss deduction, used tax incentives, or did not apply a reduced tax rate.
The simplified documentation had a precisely defined and fixed structure based on the annex to the relevant guideline of the Ministry of Finance. It was not submitted automatically together with the tax return but had to be provided to the tax authority upon request, within 15 days of delivery of such request.
2025: The Tax Return as a Substitute for Simplified Documentation
The 2025 guideline introduces a conceptual shift in the approach to fulfilling transfer pricing documentation obligations. For taxpayers who do not meet the conditions for preparing full or basic transfer pricing documentation, the documentation requirement is deemed fulfilled by submitting a duly and completely completed tax return. A key element is the correct completion of the section of the tax return relating to controlled transactions with related parties.
When Is Simplified Documentation Still Required in 2025?
Although the objective of the new regulation is to eliminate the need for separate simplified transfer pricing documentation for most taxpayers, the guideline explicitly defines two situations in which this obligation still applies.
The first case is incorrect or incomplete completion of the tax return. If the taxpayer fails to properly complete the section concerning transactions with related parties, the documentation obligation is considered unfulfilled and the tax authority may request the submission of simplified documentation.
The second case concerns technical or capacity limitations of the tax return form. The form allows a maximum of 99 rows for reporting controlled transactions. If the taxpayer has a higher number of significant controlled transactions, only those with the highest value are reported in the tax return. Transactions with lower value that cannot be included due to this limitation must be documented in a separate simplified transfer pricing documentation.
Reflection of the Changes in the Tax Return Form (Table I)
The changes to the transfer pricing documentation approach are also reflected in the tax return form itself, specifically in Table I in Part II. From 2025, this table has undergone a complete redesign, as it now assumes the role previously fulfilled by the separate simplified transfer pricing documentation. What was formerly a largely formal overview has become a detailed analytical tool through which the tax authority obtains comprehensive information on a taxpayer’s controlled transactions.
- One of the key changes is the expanded identification of counterparties. Each individual row must now include the name of the related party involved in the controlled transaction, as well as the country code of its tax residence. These details were not required in Table I for the 2024 tax year, significantly increasing the scope of reported information in 2025.
- Another significant change is the mandatory categorisation of each controlled transaction using a predefined code list. Each transaction must be assigned one of 34 specified codes covering a broad range of transactions, from the sale of goods and provision of services, through financial transactions such as cash pooling or interest, to specific compensatory and balancing adjustments. Correct classification is therefore essential for proper completion of the table.
- Table I also requires the indication of the financial impact of each transaction on the profit or loss or on the tax base. Costs must be reported as negative values and revenues as positive values.
The guideline also allows controlled transactions of the same type and concluded under comparable conditions to be grouped together. However, even when grouping is applied, transactions must still be broken down by individual related parties in the tax return, which again increases the demands on accuracy and systematic data processing.
Practical Summary
For accountants, tax advisors and entrepreneurs, this change primarily represents a shift of focus from preparing separate narrative documents to the process of completing the tax return itself. The key element becomes the correct and complete processing of data on controlled transactions directly in Table I.
If, in the tax return for 2025, the taxpayer correctly identifies all related parties, assigns appropriate codes to individual transactions according to the code list, and accurately quantifies their impact on profit or loss or on the tax base, the statutory obligation relating to simplified transfer pricing documentation is considered fulfilled.
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