Reliable Advisory and Compliance Solutions for Intercompany Transactions

As globalization expands, transfer pricing is becoming a key area of interest for tax authorities in Slovakia and abroad. Correct pricing between related parties is therefore essential for compliance with legislative requirements and minimization of tax risks.
At BDO, we offer comprehensive transfer pricing services grounded in practical experience, technical expertise, and the latest legislation, all in line with OECD recommendations. We assist companies in implementing effective, tax-optimized transfer pricing policies that adapt to a rapidly changing business environment.

 

Our Transfer Pricing Services

Transfer Pricing Compliance Services

• Preparation of transfer pricing documentation by transaction type, in accordance with local and international tax regulations
• Comparability analysis (benchmark) using  reputable databases (in relation to production, distribution, services, intangible assets, and various forms of financing)
• Permanent establishment – attribution of profits to permanent establishments in accordance with OECD methodology
• Benefit test – preparation of a defense file in relation to services received from related parties

 

TP Advisory Services

• Efficiency Analysis – identification and quantification of legitimate business reasons affecting short-term decline in profitability
• Tax audits – representing clients during tax proceedings or proceedings related to extraordinary remedies (review of tax rulings, administrative lawsuit, MAP/EUAC)
• Tax due diligence – assessment of risks with regard to intra-group pricing, risk profiles of related parties, and appropriate profitability
• Restructuring, exit tax, exit charge – advisory services on transferring business activities abroad, including assessment of tax implications and determination of the market value of transferred activities in accordance with OECD recommendations
• Advance Pricing Agreements (APA) – preparation and representation in proceedings for approval of the use of pricing methods (unilateral / bilateral / multilateral APA)
• Setup of intragroup TP arrangements – planning and implementing transfer pricing models (analysis and harmonization of procedures within the group, preparation of internal guidelines and contracts) tailored to the needs of the company and sector specifications
• Other tax advisory on business models and specific situations, e.g. DAC6 reporting, top-up tax (Pillar II) and other

Benefit from our professional experience to create a transparent and defensible TP policy that will stand up to tax audits while supporting your business goals.