TRANSFER PRICING

You are here:

Transfer pricing is not just about documentation. We can represent you during tax audits and dispute resolutions. We advise on the planning and implementation of transfer pricing models into life. We assist not only Slovak clients, but also harmonize the methodology for multinational companies and their cross-border transactions.

Transfer pricing gained attention in Slovakia in 2015, when Slovak tax law stipulated to keep documentation not only for foreign companies but also for domestic companies and persons.

We are a family owned advisory firm with an international presence due to the membership in the Moore Global Network Limited network. We have the capacity, experience and smart people who can create added value for your business. We can save you time and minimize your concerns about transfer pricing, so that you can solely focus on your business activities. It doesn’t matter whether you are a domestic or foreign client.

What can we do for you?

  • The development of transfer pricing documentation in all scopes.
  • We review your current documentation or pricing and propose a solution.
  • We advise you when you are setting up a transfer pricing model and new policy.
  • We will provide you a comparability analysis because we have access to RoyaltyRange or Orbis databases.
  • We can represent you during the tax audit.
  • We can assist you with advance pricing agreements (APA).
  • We are able to organize a training for you where we share our experience and know-how.

Our added value

  • Synergy and cooperation within the Moore Group allows us to work on international projects.
  • Individual approach and price offer tailored to your needs.
  • The complexity in providing our services. We understand taxes, accounting and auditing. Everything under one roof.
  • We have experience in several industries – automotive, food, real estate, financial sector, energy and IT sector.
  • Experience and reliability. We are not beginners. We have been on the market for more than 30 years and provide transfer pricing consulting services since 2014.
  • We speak English, German, Hungarian and French.
  • We have a personal approach and an experienced and stable team.

We are a people oriented firm. Get to know our people with whom you will communicate.

Krejzová

Laura Krejzová
Tax Manager

Laura has more than seven years of experience in the field of income tax and VAT. She participates in several tax and accounting audits every year. She orients herself in international taxation and provides more complex tax advice for international clients. Moreover, she work on transaction consulting projects such as M&A, contributions in kind or sales of parts of companies. Laura is a graduate of Matej Bel University, major: Finance, banking, investing with a specialization in audit, accounting and financial management. She is fluent in English and French. She already become familiar with transfer pricing at university and since then she has been preparing documentation for clients from various industries.

Kapusta

David Kapusta
Transfer pricing specialist and assistant tax advisor

Our transfer pricing specialist. David is a graduate of law studies (Matej Bel University) and finance and accounting (Rotterdam University of Applied Science, Prague University of Economics). For more than five years, the focus of his work has been the preparation of transfer documentation and the setting up transfer pricing policies. He performs benchmarks, comparability and industrial analyses and assists clients with filling Country by Country Reporting (CbCR) obligations and advance pricing agreements (APA). David also specializes in benchmarking of loans and financial transactions. He has experience not only with international clients, but also with domestic companies.

What type of documentation does your company need? Take a short test and found out more.

1 Step 1
1.) Did your company perform any of the following actions in relation to a transaction with a related company or person?
2.) Is your company obliged to report the financial statements according to international accounting standards (IFRS) and at the same time did your company carry out a significant cross-border transaction (e.g. 1% of turnover)?
3.) Did your company carry out a cross-border transaction with a related company or person whose value exceeded 10 million euros?pick one!
4.) Has your company achieved total revenues more than 8 million euros from economic activity and financial activity and at the same time carry out a significant cross-border transaction with a related company or person (e.g. 1% of turnover)?pick one!
5.) Did your company carry out a cross-border transaction with a related company or person whose value exceeded 1 million euros?pick one!

Full scope documentation. Your company probably has an obligation to keep transfer documentation in full scope. It is the most complex documentation containing detailed transaction analysis, benchmark analysis, application of transfer pricing methods and extensive group information.

Basic documentation. Your company probably has an obligation to keep basic transfer documentation. This is documentation containing a detailed description of transactions and the application of transfer pricing methods.

Simplified documentation or proper completion of the income tax return. Your company will probably meet the documentation requirements by keeping simplified and shortened documentation or just by completing the tax return properly.

keyboard_arrow_leftPrevious
Nextkeyboard_arrow_right
FormCraft - WordPress form builder

Please note that the test has indicative nature and does not include all possible scenarios. When determining the scope of the transfer documentation, other facts are not taken into account in this test, such as the application of tax relief or transactions with non-contracting states. The rules are different for natural persons and state entities. For an accurate assessment of documentation obligations, please do not hesitate contact us.

Update on transfer-pricing developments

The latest Amendment to the Income Tax Act introduced several substantial changes in transfer pricing area in Slovakia. The most of changes have come into effect from 1 January 2023. In addition, the Slovak Ministry of Finance announced updated guidelines defining the contents of transfer pricing documentation. The changes which will start to apply from…

Transfer Pricing Update

Has your business been affected by the COVID-19 pandemic? It may also have an impact on your transfer pricing. Companies have been experiencing fluctuations in revenues and cash flows and facing forced closures during the pandemic. On the other hand, certain segments and companies have strengthened their position significantly. Many countries have intervened and provided…

Production models

Manufacturing activities in a group can be organized in different forms. In general, we distinguish four basic models, namely: a full-fledged producer, a manufacturer with limited powers, a contracted manufacturer, and wage labor. A full-fledged manufacturer carries out all manufacturing activities, from the design of the product to the final sale to the customer. This…

New edition of the OECD Transfer Pricing Guidelines

On 10 July 2017, the OECD released a new revised edition of its Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. The introduced changes are significant globally since the OECD Guidelines represent the major and most reputable regulation resource on transfer pricing. The new edition especially includes the changes that were approved during 2015…