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Slovakia | 61

Do tax authorities have related transactions) in both directions Advance pricing
requirements or preferences are used. In general, it is expected that arrangements
regarding databases for a year-end adjustment is described/
comparables? anticipated in relevant agreements What APA options are available, if
The tax authorities in Slovakia use the covering intra-group transactions and any?
Amadeus database. specifc formulae/calculations are in
place. Unilateral.
What level of interaction do tax Is there a fling fee for APAs?
authorities have with customs Other unique attributes?
authorities? Not applicable. No/immaterial.
Regarding corporate income tax, the Other recent Does the tax authority publish APA
interaction of the tax authorities with the data either in the form of an annual
customs authorities is low. However, the developments report or through the disclosure of
responsibilities of both authorities can data in public forums?
lead to a higher level of interaction in the The Slovak central tax authorities have No.
area of VAT. built a transfer pricing department
and therefore more focus by the
Are management fees deductible? tax authorities on transfer pricing is Please provide some information
expected in the near future. on how successful the APA program
In general, yes, but subject to is and whether there are any known
documentation requirements and Tax treaty/double tax diffculties?
justifcation of how the management It is not common in Slovakia to ask for
services serve to generate, assure or resolution an APA.
maintain taxable income of the Slovak
company. What is the extent of the double tax Language
treaty network?
Are management fees subject to Extensive. The current double tax treaty In which language or languages
withholding? network includes 64 tax treaties. New can documentation be fled?
In general no, but if these also comprise tax treaties are being negotiated. Documentation should be fled with
intellectual property transfer (know-how) the Slovak tax authorities in the Slovak
and this is not separately disclosed If extensive, is the competent language, but upon request of the
on invoice, then they could be subject authority effective in obtaining taxpayer the tax authorities may allow
to withholding tax. A security tax is double tax relief? the submission of the documentation
withheld in some circumstances, if Almost always. in another language.
the entity to which fees are paid has a
permanent establishment in Slovakia When may a taxpayer submit an
and is a tax resident outside the EU. adjustment to competent authority?
No formal rules. However, at the
Are year-end transfer pricing latest within four to 10 years after the
adjustments permitted? respective taxable period. KPMG in Slovakia
Yes, although the Slovak transfer pricing
legislation does not specifcally address May a taxpayer go to competent Tomáš Ciran
a term year-end adjustment. In practice authority before paying tax? Tel: +421 2 599 84 111
year-end transfer pricing adjustments Yes. Email: tciran@kpmg.sk
(refected in the same taxable period as Branislav Durajka
Tel: +421 2 599 84 303
Email: bdurajka@kpmg.sk
Zuzana Blažejová
Tel: +421 2 599 84 331
Email: zblazejova@kpmg.sk

As email addresses and phone numbers change
frequently, please email us at transferpricing@
kpmg.com if you are unable to contact us via the
information noted above.
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