Slovakia expands related-party reporting in corporate tax return

The filing deadline determines which form applies

The Ministry of Finance issued corporate return form DP PO MF/014309/2026-721 under Notice MF/014310/2026-721, published in Financial Bulletin 16/2026. The new form applies where the final day of the taxpayer's filing deadline falls after 31 December 2026. The previous corporate form, MF/012187/2025-721, continues where that day fell no later than 31 December 2026. Separate notices provide the filing confirmation and completion instructions.^[2][4]

Table I requires more related-party detail

The main change for multinational groups is redesigned Table I. Slovak taxpayers must report significant controlled transactions with domestic and foreign related parties, while taxpayers operating in Slovakia through a permanent establishment must also complete the table. Internal dealings between a head office and its permanent establishment are expressly included. For each significant transaction or transaction group, the return records the transaction code, aggregation, any head-office relationship, the tax-base effect, the counterparty's residence jurisdiction and the related party's name.^[2][3]

Statutory thresholds shape the disclosure

Section 17(5) of the Income Tax Act treats a controlled transaction or group as significant where taxable income or deductible expense exceeds EUR10,000; a loan is significant where principal exceeds EUR50,000. Related-party loans receive a separate disclosure covering the highest amount outstanding during the period, closing balance, counterparty jurisdiction and counterparty name. A further section flags smaller controlled transactions not already included within an aggregated group.^[2][3]

The return supplements transfer-pricing documentation

Where Table I lacks enough rows, significant transactions must be added to shortened transfer-pricing documentation. Taxpayers subject to full or basic documentation remain required to maintain that documentation as well as completing the return. The form also introduces Table L to reconcile booked revenue to taxable income, adds a tax-loss row to Table D and creates a section for specified card-payment fees credited to player accounts that form a special tax base under section 51eb.^[2]

Groups should map data before the first affected deadline

Multinational groups should map related-party, loan and permanent-establishment data to the new fields, identify any aggregation methodology and retain the transaction-level bridge to their transfer-pricing files. Controls should determine the applicable return by the last day of the filing deadline rather than merely by accounting period. The new form changes compliance reporting; it does not itself alter the arm's-length standard or replace the documentation required for a taxpayer's controlled transactions.^[2][3][4]