The published results confirm the high effectiveness of tax audits focused on transfer pricing.

In the first half of 2026, the Office for Selected Economic Entities (ÚVHS) completed a total of 16 tax audits focused on transfer pricing. As many as 15 of these audits resulted in findings, representing a success rate of 93.75%. The total amount of audit findings exceeded EUR 57.4 million. EUR, with more than EUR 52 million eur of which was directly related to transfer pricing.

The Slovak Financial Administration highlighted the growing trend towards the use of analytical tools and risk assessments when selecting taxpayers for tax audits.

It is therefore important for companies to:

• regularly review their transfer pricing arrangements,
• maintain well-prepared transfer pricing documentation,
• be able to substantiate the economic substance and arm’s length nature of intra-group transactions,
• be prepared for a potential tax audit.

At TPA TAX, we are happy to assist you with:

✔️ analysis of transfer pricing and cross-border transactions,
✔️ preparation of transfer pricing documentation,
✔️ setting and defending transfer pricing arrangements,
✔️ support during tax audits and communication with the tax authorities.