Coca-Cola HBC deducted management fees paid to an Austrian group entity in 2004, but Slovak tax authorities disallowed a portion as non-arm's length and extended the assessment period using the Austria-Slovakia tax treaty. The Slovak Administrative Court ruled in the taxpayer's favour in 2025, finding the standard five-year limitation period had expired and that Article 9 of the tax treaty could not extend it, annulling the transfer pricing adjustment ... Read more

A Slovak agricultural company acting as both lender and borrower in intra-group loan arrangements charged interest at 0.6 per cent on loosely structured agreements with no fixed terms. The tax authority found this rate failed the arm's length standard given the borrowers' weak financial position and high credit risk, adjusted the rates using National Bank of Slovakia sector averages, and increased the corporate income tax base. The Administrative Court upheld the assessment in full ... Read more

Following a tax authority audit, Coca-Cola HBC Česko a Slovensko challenged additional assessments relating to intra-group loans reclassified as equity, denied interest deductions, and disputed management service cost allocation keys. The company also raised procedural objections regarding new analyses introduced at appeal stage. The Slovak Administrative Court ruled in favour of the taxpayer in May 2025 ... Read more

A Slovak company submitted transfer pricing documentation relying on a full-range benchmark, but tax authorities found 9 of 10 comparables lacked independence. The authorities conducted their own TNMM benchmark, concluded the controlled transactions fell outside the interquartile range, and adjusted pricing to the median. The Administrative Court dismissed the taxpayer's appeal in March 2025, upholding the assessment in full ... Read more

A Slovak contract manufacturer within the Valeo group was subject to a transfer pricing adjustment by the tax authorities, who applied TNMM with an interquartile range and median benchmark and disallowed deductions for intra-group management and technical service fees. The Administrative Court rejected the company's appeal, and the Supreme Administrative Court dismissed the further appeal in September 2024, fully upholding the tax authority's assessment ... Read more

IKEA Industry Slovakia, a contract furniture manufacturer within the Swedwood group, was assessed additional corporate income tax after Slovak tax authorities rejected its CUP method and applied TNMM, finding its reported losses fell outside the arm's length range. The Slovak Administrative Court ruled in favour of the taxpayer in September 2024, finding flaws in the benchmarking comparability analysis conducted by the tax authorities ... Read more

A Slovak company claimed deductions for advertising expenses routed through a chain of intermediaries, which the tax authority found added no value and served primarily to reduce taxable income. Applying the CUP method, the authority adjusted the company's taxable income. The Supreme Administrative Court upheld the assessment in 2024, finding the company failed to demonstrate a genuine business rationale for the inflated costs ... Read more

A Slovak aluminium castings manufacturer within the Alicon Group used the profit-split method and reported a loss in 2012/2013. Tax authorities reclassified the company as a limited-risk manufacturer and applied TNMM, rejecting the reported loss. The Administrative Court ruled largely in the taxpayer's favour in 2024, finding authorities failed to prove limited-risk entities cannot incur losses and identified flaws in the benchmark study, including improper exclusion of loss-making comparables ... Read more

A Slovak Administrative Court ruled in favour of Marelli Slovakia in a 2024 transfer pricing case concerning intra-group sales of automotive components for FY 2012. The tax authority applied the TNMM and argued the company bore risks without control or decision-making power. The court sided with the taxpayer, addressing comparability analysis, risk allocation, and the legal status of the OECD Transfer Pricing Guidelines ... Read more

A Slovak contract manufacturer within the FIVAC Group had trademark royalty payments partially disallowed by tax authorities, who argued no royalty was justified on products sold to related parties. A 10% profit margin on recharged ORACLE software licences was also rejected. The Administrative, Regional, and Supreme Courts all dismissed the taxpayer's appeals. In 2021, the Slovak Constitutional Court confirmed those decisions, ruling in favour of the tax authority ... Read more

A Slovak contract manufacturer paid trademark royalties and charged-on Oracle software licence fees with a 10% markup to related parties. The tax authority disallowed 90% of the royalties, attributable to intra-group sales, and rejected the software licence markup as unjustified. The Administrative Court, Regional Court, and ultimately the Supreme Court in January 2021 all upheld the tax authority's position, confirming no deduction was warranted ... Read more

A Slovak contract manufacturer in the FIVAC Group paid trademark royalties and charged ORACLE software licence costs with a 10% profit margin to related parties. The tax authority disallowed royalties attributable to intra-group sales and rejected the licence mark-up as unjustified. The Regional Court of Nitra upheld the tax authority's position in full, confirming both disallowances in its March 2019 judgment ... Read more

A Slovakian Coca-Cola subsidiary deducted management, employment, and IT service fees paid to a Swiss group entity. The Slovak tax authority challenged the deductions relying on the OECD Transfer Pricing Guidelines. The Supreme Court of the Slovak Republic ruled mostly in favour of the taxpayer, holding that the OECD Guidelines and Commentary are non-binding recommendations under Slovak law unless formally published in the official collection of laws ... Read more

A Slovak tax authority applied the OECD Model Commentary's beneficial ownership concept to restrict treaty benefits for non-resident income, despite the treaty containing no such requirement. The Supreme Court of the Slovak Republic held in 2015 that OECD Commentaries are not legally binding under national or international law unless formally incorporated, and that taxpayers cannot be expected to follow unpublished or untransposed interpretive rules ... Read more