he Financial Administration of the Slovak Republic published the results of tax audits conducted by the Office for Selected Economic Entities (OSEE) in the first half of 2026. The OSEE completed 16 corporate income tax audits focused on transfer pricing, of which 15 – i.e. 93.75% – resulted in findings. The cumulative amount of the findings reached EUR 57.41 million, of which the findings specifically related to transfer pricing amounted to EUR 52.08 million.
These figures are an important signal for businesses carrying out significant transactions with related parties. The Financial Administration also expressly states that the high success rate of the audits is related to the effective use of analytical tools in the selection of entities, its own analytical assessments, and an in-depth assessment of their risk profile.
▢ Why is transfer pricing in the spotlight?
Transfer pricing may have a significant impact on the allocation of profits within a group and, consequently, on the tax base reported in Slovakia. At the same time, it is an area in which the Financial Administration has access to an increasingly broad range of structured data and analytical capabilities for identifying potential discrepancies.
Based on our experience, it is therefore no longer sufficient to have only formally prepared transfer pricing documentation. What is particularly important is the consistency of the data reported in the tax return, accounting records and transfer pricing documentation, as well as their consistency with the actual economic substance and the set-up of intra-group transactions.
▢ Which areas may increase the risk of a TP audit?
1) Profitability and financial performance
Particular attention in risk assessment may be attracted by persistently low profitability or recurring tax losses of a Slovak company, especially if they do not correspond to its functions, assets and risks or to the development of the group’s business. A significant deviation in profitability from comparable companies or a sudden change in the margin without an apparent economic reason may also be a risk indicator.
2) Significance and nature of controlled transactions
The more significant the volume of transactions between related parties and their impact on the Slovak tax base, the greater their relevance may be in the assessment of tax risk. In practice, particular attention should be paid, for example, to intra-group services, financing and interest, royalties, distribution and manufacturing models, as well as restructurings and transfers of functions, risks or intangible assets.
The OSEE administers selected economic entities that are among the largest taxpayers in Slovakia, such as banks, insurance companies and companies with annual turnover exceeding EUR 40 million. According to the Financial Administration, these companies often operate in an international environment, have complex structures and carry out complex transactions.
3) Data consistency and analytical selection of entities
We consider the shift towards data-driven selection of entities to be particularly important. The Financial Administration has directly confirmed the use of analytical tools, its own analytical assessments and an in-depth assessment of risk. In practice, this means that discrepancies between individual data sources may be identified even before the tax audit itself begins.
Therefore, as part of an internal TP risk assessment, we recommend reviewing in particular:
- whether the data on controlled transactions in the tax return correspond to the accounting records and transfer pricing documentation;
- whether the profitability achieved is consistent with the functional and risk profile of the Slovak company and the TP method applied;
- whether significant year-on-year changes in prices, margins or the volume of intra-group transactions can be economically explained;
- whether intra-group services, financing, licences and other significant payments are sufficiently documented and defensible; and
- for multinational groups, whether the locally reported data create any apparent discrepancies with information available to the tax authority through the international exchange of information, including CbCR, where relevant for the group.
▢ What does this mean for taxpayers?
The result of 15 findings out of 16 completed audits cannot automatically be applied to all taxpayers – these are audits of entities that had already been selected based on the OSEE risk assessment. However, this fact itself shows that analytical selection can be highly effective. The Financial Administration has also announced that it will continue its audit activities focused on transfer pricing in the second half of 2026.
We therefore recommend not waiting until a tax audit is announced. An appropriate step is a preventive TP health check – a review of the pricing arrangements, profitability achieved, documentation and, in particular, the consistency of data that the Financial Administration has or may have at its disposal. The objective is to identify and explain any potential risk indicators before they become the subject of an audit.
▢ How can we help you?
We would be pleased to assist you with a preventive assessment of TP risks, the setting or review of transfer prices, benchmarking, the preparation of transfer pricing documentation, as well as support during a tax audit.
At Moore Slovakia, transfer pricing is handled by a team of experts:
Martin Kiňo – Partner I martin.kino@moore-slovakia.sk
Elena Olejníková – Head of Tax I elena.olejnikova@moore-slovakia.sk
Michal Ištok – Transfer Pricing Expert I michal.istok@moore-slovakia.sk
Source: Financial Administration of the Slovak Republic, press release “OSEE Confirms High Effectiveness of Transfer Pricing Audits”, 22 July 2026.
