Under Slovenian tax regulation a taxpayer shall provide and keep supporting transfer-pricing documentation with the information on related parties, business transactions with these entities and types of methods used to determine comparable market prices. A tax payer needs to verify, adjust and complete transfer pricing documentation in a form suitable to present it to Slovenian Tax Authorities. Cautela Pros is providing the following transfer pricing services:

  • Definition and determination of related parties according to provisions of Slovenian tax legislation
  • Selection of appropriate transfer pricing method
  • Preparation of supporting transfer pricing documentation including reasoning for appropriate method selection in line with functional and risk profile of tax payer
  • On your request we can perform revision of existing transfer pricing documentation and transfer pricing policy and comment on any risk exposure from transfer pricing system

The documentation for the transactions aims to achieve the following objectives in order to:

  • Develop transfer pricing documentation in a cost efficient way, which:
    • covers the main inter-company transactions
    • covers the main steps of a transfer pricing analysis
    • take appropriate decisions (e.g. method selection, benchmark criteria, etc.)
    • is supported with reliable comparables
    • is in line with the functional and risk profile of taxpayer
  • Comply with the OECD Transfer Pricing Guidelines and with Slovene specific transfer pricing rules
  • Sustain transfer pricing methodology in line with the organizational characteristics of tax payer
  • Minimize the risk of potential profit adjustments (penalties and interest)
  • Mitigate the risk of adverse penalties for lack of proper documentation
  • Facilitate a documentation maintenance policy
  • Facilitate the consistent disclosure of information to tax authorities.

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