Slovak transfer pricing legislation and its changes from 2026

1. New Guidelines from the Ministry of Finance of the Slovak Republic

At the end of 2025, the Ministry of Finance of the Slovak Republic issued a new Guideline on determining the content of transfer pricing documentation (No. MF/012879/2025-724), which replaces the existing Guideline effective from 2023 (No. MF/020061/2022-724).

The new Guideline will apply for the first time when preparing transfer documentation for a tax year, for which the last day for filing the tax return falls after 31 December 2025.

2. Changes compared to existing documentation obligations

The new Guideline of the Ministry of Finance of the Slovak Republic maintains the existing structure of transfer documentation, i.e. the distinction between full, basic and abbreviated documentation, as well as the basic criteria determining its scope. At the same time, however, it introduces several significant changes that have a practical impact on taxpayers.

Aggregation of controlled transactions

The Guideline introduces the principle that multiple controlled transactions may be grouped together and treated together under certain conditions.

A key clarification in the new Guideline compared to the previous regulation is that these transactions can be treated as one group even if they are performed with different counterparties. This definition strengthens the legal certainty of taxpayers in rational and justified aggregation of transactions, if such an approach leads to a more faithful and reliable representation of the transfer pricing methods used. At the same time, however, the aggregation of transactions must be properly and clearly justified in the transfer documentation.

Changes to abbreviated documentation

Until now, abbreviated documentation was required in cases where the tax entity did not keep complete or even basic documentation, especially for significant controlled transactions and in specific situations, for example, when a tax loss was declared, claimed or when a certain tax rate was applied.

With the new Guideline, a simple rule applies, if a taxpayer does not fall under the full or basic documentation regime, his obligation is fulfilled by properly completing the tax return. However, if this obligation is not fulfilled, the taxpayer is obliged to keep abbreviated documentation of significant controlled transactions in the structure set out in the Annex to the Guideline.

In practice, this reduces the number of cases where abbreviated documentation will be mandatory and at the same time increases the emphasis on correct, complete and accurate reporting of transactions in the tax return itself.

3. New reporting of transactions in the tax return

With the increased emphasis on reporting transactions with related parties in the tax return itself, the scope of the information provided about these transactions in the tax return is also expanding.

If you would like more detailed information on these issues, please do not hesitate to contact our experts who will be happy to provide you with further support.