A trap for companies? 94% struggle with transfer pricing tax audits

Companies in Slovakia are paying the price for a lack of transfer pricing know-how. “In the first half of 2026, as many as 15 out of 16 transfer pricing tax audits ended with findings,” warns a Forvis Mazars expert. Where are the biggest pitfalls?

As many as 15 of the 16 tax audits examining the correctness of transfer pricing in the first half of 2026 ended with findings. In other words, almost 94% of the audited companies failed. “Transfer pricing is one of the areas the tax administrator pays particular attention to during tax audits,” says Ulrika Gajdošová, tax expert at Forvis Mazars in Slovakia. The outcome of an audit often depends not only on how prices are set, but also on how well the company is prepared for it. “For example, whether it has complete and up-to-date documentation, whether it can demonstrate the justification and benefit of the intra-group services it receives, and whether it can submit the requested documents to the tax administrator on time,” explains Ulrika Gajdošová.

Is the problem related parties or paying taxes?

Transfer pricing is governed by Act No. 595/2003 Coll. on Income Tax and the related guidelines. Its purpose is to make the process of setting prices for goods, services, assets or loans in business transactions between related parties transparent. Related parties are not only family members, but also persons connected through ownership, personnel or other ties. The rules aim to prevent more favourable pricing within such relationships, as well as the artificial shifting of profits or costs between companies in order to avoid paying taxes properly. “If the value of a transaction exceeds EUR 10,000, it must comply with the arm’s length principle, meaning the price that independent parties would agree on. In practice, this means it has to be compared with market prices,” explains Ulrika Gajdošová. Companies are therefore required to keep transfer pricing documentation if the value of a transaction exceeds EUR 10,000, or EUR 50,000 in the case of loan and credit principals. At the same time, the scope of data reported in the tax return is expanding. This gives tax offices a better overview and increases both the likelihood of an audit and the need to defend the prices set. So what do companies struggle with? “Practice shows that companies face several transfer pricing challenges. That is also why we have prepared a series of free webinars for them,” says the Forvis Mazars expert.

Free webinars for companies

From 27 October to 10 December 2026, Forvis Mazars, with the support of the French-Slovak Chamber of Commerce (CCFS), is organising a series of five free 30-minute webinars (held in Slovak). Using practical examples, they show what companies should prepare for during tax audits. “The opening webinar will present the changes in the new Table I of the corporate income tax return and their impact on reporting controlled transactions. The other four parts focus on transfer pricing tax audits, from their initiation and the submission of documentation, through the most common findings, to lessons learned from court decisions. Instead of extensive theory, we will focus on specific situations and experience from audits in which we have supported our clients,” notes Ulrika Gajdošová.

The webinars are particularly suitable for companies that are part of international or domestic groups and carry out transactions with related parties. These include, for example, manufacturers and suppliers in the automotive and engineering industries, distribution and trading companies including retail, shared service centres, companies providing or receiving intra-group services (such as management, IT or accounting services), companies with intra-group financing (loans, cash pooling) or royalties, and companies that have been reporting losses over the long term or have undergone restructuring within their group. “Within these companies, the webinars are aimed primarily at CFOs, tax and accounting specialists and controllers who want to be prepared for a tax audit,” adds the Forvis Mazars expert. Forvis Mazars can also help companies review their transfer pricing documentation and transfer pricing setup, and provide comprehensive professional support in communicating with the tax administrator, preparing requested documents, opinions and responses to the tax administrator’s findings, and representing clients in proceedings before the tax administrator.

Find out more about the webinars here.

About Forvis Mazars

Forvis Mazars Group SC is an independent member of Forvis Mazars Global, a leading global professional services network. Operating as an internationally integrated partnership in over 100 countries and territories, Forvis Mazars Group specialises in audit, tax and advisory services. The Group draws on the expertise and cultural understanding of more than 40,000 professionals worldwide to help clients of all sizes at every stage of their development. Forvis Mazars in Slovakia is part of Forvis Mazars Group SC. Find out more at www.forvismazars.com/sk/en and follow Forvis Mazars on LinkedIn.