New Table I in the tax return: what changes for transfer pricing

For 2026, companies will report transactions with related parties in a new, more detailed Table I of the corporate income tax return. The table now covers financial transactions, new transaction types and an obligation to flag aggregated transactions. In the first part of our transfer pricing webinar series, Ulrika Gajdošová, Transfer Pricing Manager at Forvis Mazars in Slovakia, explained the changes. This article brings you the key answers.

Why it matters

Why is it worth paying attention to transfer pricing right now?

The Financial Administration has published that in the first half of 2026, the Office for Selected Economic Entities completed 16 corporate income tax audits focused on transfer pricing. As many as 15 of them ended with an assessment, a success rate of 93.75%. The additional assessments totalled EUR 52 million, an average of EUR 3.47 million per case.

What will the tax administrator use the new Table I for?

The tax administrator will have the data from Table I available immediately after the tax return is filed. The more detailed data will allow it to review transactions, link them to the financial statements and use various indicators to assess whether a taxpayer is high-risk. Table I will also help it check withholding tax, as items such as royalties are reported in it.

Structure of the new Table I

How does the new Table I differ from the one for 2025?

The new Table I has three parts:

1. ordinary controlled transactions, such as the purchase and sale of goods, materials or services;
2. financial transactions, i.e. loans and borrowings, which until now were reported only in aggregate, usually as interest;
3. a checkbox for insignificant transactions that are not reported in the table.

You can enter a maximum of 99 rows in both the first and the second part. If that is not enough, the obligation to report the remaining transactions above the set thresholds still applies. This is usually addressed through abbreviated documentation, which is a separate form under the Ministry of Finance of the Slovak Republic guideline on the content of documentation.

How do I complete the first part with ordinary transactions?

For each transaction, you state its impact on the profit or loss: income as a positive number, expenses as a negative number with a minus sign. You also state the code of the country in which the related party is tax resident. Completing the table incorrectly can have consequences in a tax audit.

What new transaction types have been added?

Compared with 2025, three transaction types have been added:

• transfer of a business or a part of it;
• sales support services;
• asset or portfolio management services.

The other transaction types remain unchanged. If a transaction cannot be classified under any of them, it is reported under code 37 as other transactions.

What goes in column 4?

Column 4 is new. You mark it with a cross to indicate a relationship between a head office and its permanent establishment, or between permanent establishments of the same taxpayer. A head office with a permanent establishment abroad reports its own transactions as well as those it allocates to the permanent establishment.

What transaction value should I report?

The value of a controlled transaction is now reported as its impact on line 400 of the tax return, not on line 100 as in 2025. The change reflects the fact that some transactions are not reported in Table I.

If a transaction during the year was not in line with the arm's length principle and you adjust it on line 110 of the tax return, you report the adjusted value in Table I, i.e. the value in line with the arm's length principle.

Aggregation of transactions

What does the new column for aggregating transactions mean?

In column 3, you mark transactions that you consider to be a group of controlled transactions. The concept is based on the Ministry of Finance of the Slovak Republic guideline on the content of documentation for 2025. A group consists of several controlled transactions, including transactions with different related parties, that meet criterion A together with criterion B or C:

• A: they are of the same type and concluded under comparable conditions;
• B: they are closely interlinked and mutually dependent;
• C: they are comparable in terms of the assets used, functions performed and risks assumed.

Until now, aggregation was usually assessed by tax advisors when preparing transfer pricing documentation. Now the taxpayer has to decide on it as early as when filing the tax return.

How do I report aggregation in practice?

For example, if your company buys goods from three related parties under comparable conditions, you report each transaction in a separate row with its own value and counterparty, and mark column 3 in all three rows.

Pay attention to consistency with your transfer pricing documentation. If you report transactions as a group in Table I, the tax administrator will expect you to describe and test them together in the documentation.

How will aggregation affect the scope of transfer pricing documentation?

When assessing materiality, the values of the transactions in a group are added together. If three cross-border purchases together exceed EUR 1 million, you are required to keep basic documentation. If they exceed EUR 10 million, full documentation is required.

Aggregation also changes how small transactions are reported. You would otherwise not have to report a transaction of up to EUR 10,000, but if you include it in a group, you must report it in Table I and mark it as part of the group.

Financial transactions and insignificant transactions

How do I report loans and borrowings in the second part of the table?

The second part is entirely new and distinguishes five types of financial transactions. For each of them, you state:

• the highest principal amount during the tax period;
• the balance of the loan or borrowing as at the last day of the tax period;
• the country code and the name of the related party.

For standard loans, determining the highest amount is simple. Cash pooling requires more care, as you need to select the highest principal value for the whole period from the daily balances.

For a permanent establishment, you state the full name of the head office with the designation SP. If the permanent establishment is registered in the Commercial Register as an organisational unit, you state its full name as registered in the Commercial Register.

What is the third part of the table for?

You tick the box if you also have controlled transactions that you do not report in the table because they are insignificant. These are ordinary transactions of up to EUR 10,000 and financial transactions with a principal of up to EUR 50,000.

Which transactions are not reported in Table I?

The following are not reported in Table I:

• insignificant transactions of up to EUR 10,000, or up to EUR 50,000 for financial transactions, unless they are part of an aggregated group;
• transactions exempt from tax under the Income Tax Act, such as the sale of a business share with exempt income;
• permanent non-deductible expenses that are never included in the tax base, such as entertainment expenses.

Temporary differences, such as provisions, on the other hand, are reported, and in the period in which they were booked, not in the following year when the invoice is received.

What if I am not sure whether to report a transaction?

For specific transactions, we recommend contacting the Financial Administration directly. It plans to publish guidance summarising its answers to specific questions from taxpayers. It had not yet been issued at the date of the webinar.

Want to know more?

The transfer pricing team at Forvis Mazars in Slovakia prepares transfer pricing documentation (local file and master file), benchmarking studies in the TP Catalyst and Bloomberg databases, reviews contracts and transaction set-ups, and supports clients during tax audits, including representation under a power of attorney. If you need help with the new Table I, we are here for you.