{"id":10032,"date":"2026-09-10T16:21:28","date_gmt":"2026-09-10T14:21:28","guid":{"rendered":"https:\/\/www.moore-bdr.sk\/?p=10032"},"modified":"2026-09-18T14:11:40","modified_gmt":"2026-09-18T12:11:40","slug":"transferove-ocenovanie-pod-drobnohladom-financnej-spravy-15-zo-16-kontrol-skoncilo-s-nalezom","status":"publish","type":"post","link":"https:\/\/www.moore-bdr.sk\/en\/transferove-ocenovanie-pod-drobnohladom-financnej-spravy-15-zo-16-kontrol-skoncilo-s-nalezom\/","title":{"rendered":"Transfer pricing under close scrutiny by the financial administration: 15 out of 16 audits resulted in findings"},"content":{"rendered":"

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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 \u2013 i.e. 93.75% \u2013 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.<\/p>\n

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.<\/em><\/span><\/p>\n

\u25a2<\/span> Why is transfer pricing in the spotlight?<\/strong><\/p>\n

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.<\/p>\n

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.<\/p>\n

\u25a2 <\/span>Which areas may increase the risk of a TP audit?<\/strong><\/p>\n

1) Profitability and financial performance<\/strong><\/p>\n

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.<\/p>\n

2) Significance and nature of controlled transactions<\/strong><\/p>\n

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.<\/p>\n

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.<\/p>\n

3) Data consistency and analytical selection of entities<\/strong><\/p>\n

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.<\/p>\n

Therefore, as part of an internal TP risk assessment, we recommend reviewing in particular:<\/p>\n