Page 64 - Central and Eastern European Transfer Pricing Review

64 | CEE Transfer Pricing Review

Do tax authorities have requirements Other recent Is there a fling fee for APAs?
or preferences regarding databases developments Not applicable.
for comparables?
The tax authority uses the Amadeus In January 2012 a change in the transfer Does the tax authority publish APA
pricing rules occurred. There are some
database for searching for comparables, changes with respect to priority amongst data either in the form of an annual
but also other databases are accepted. report or through the disclosure of
transfer pricing methods and there are data in public forums?
What level of interaction do tax also amendments regarding tangible Not applicable.
authorities have with customs assets and other minor issues.
authorities? Please provide some information
High. Tax treaty/double tax on how successful the APA program
resolution is and whether there are any known
Are management fees deductible? diffculties?
Yes, under the condition that appropriate What is the extent of the double Not applicable.
agreements are in place and that a tax treaty network?
taxpayer can prove that services were Extensive. Language
actually needed and rendered.
If extensive, is the competent In which language or languages
Are management fees subject to authority effective in obtaining can documentation be fled?
withholding? double tax relief? In general, the documentation needs
No. No experience in transfer pricing feld. to be in Slovene language. However,
Slovenia competent authority has limited it could also be prepared in a foreign
Are year-end transfer pricing experience in MAP, and it is too early language but translated upon the
adjustments permitted? to tell how successful they are in such tax authoritys request, within the
Yes, year-end adjustments are permitted resolutions. deadline set by the tax authority
either in the CIT return (artifcial increase (no earlier than in 60 days).
of the tax base due to transfer prices) or When may a taxpayer submit an
in the fnancial statements (credit note, adjustment to competent authority?
debit note). Credit or debit notes have Prior to the commencement of the tax
potential VAT and customs implications. audit (self announcement procedure).
For incorrect reporting/calculation of
taxes due to transfer prices, penalties May a taxpayer go to competent
may apply according to VAT and authority before paying tax?
customs legislation. Not applicable for transfer pricing.

There should be no penalties arising from
transfer prices if transactions between Advance pricing
related parties are at arms length. arrangements
Other unique attributes? What APA options are available,
No. if any?
No APAs or binding rulings of any kind.

KPMG in Slovenia

Nada Drobnič
Tel: +386 1 4201 149
Email: nada.drobnic@kpmg.si

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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