Worldwide transfer pricing reference guide 2014

Slovenia (continued)
Documentation requirements
The Slovenian transfer pricing documentation requirements are based on the Masterfile concept. Under this concept, as recommended
by the European Community (EC) Council as well as the EU Joint Transfer Pricing Forum, the transfer pricing documentation should
consist of a Masterfile and a country-specific file. Disclosure of any related party transaction amounts should be provided along with the
tax return when it is filed with the tax authority.
The local legislation sets the following documentation requirements:
The master file
The master file normally includes documentation common to the whole group. It may be prepared by the group’s headquarters and
should include a general description of the way business is conducted by the group companies. The file should include the following:
• A description of the taxable person
• A description of the global organizational structure of the group
• An explanation of the type of connections between the companies in the group
• An explanation of the method used in the determination of transfer prices
• A description of the business activities and business strategies (including any general economic and other factors, an assessment of the
competitive environment, etc.)
Country specific documentation
The local documentation should describe the company’s course of business, but on a local level. The country-specific documentation
should normally include:
• A description of transactions between affiliated persons
• A functional analysis determining the main functions performed and risks undertaken by the taxpayer, and outlining which adjustments
may need to be made in relation to comparable situations
• A description of any comparable search performed
• A description of business strategies
• A description of goods/services transferred/rendered
• A description of the method applied for establishing the arm’s length price
• Any other information that might be relevant from the transfer pricing perspective should also be included in the documentation
Documentation deadlines
The documentation should be provided to the tax authority upon request, usually made in the course of a tax audit. If it is impossible to
submit the documentation immediately, an extension of up to 90 days (depending on the extent and complexity of the information) may
be granted. If the Masterfile is not kept in the Slovenian language, the tax authority may request a translated version before submission.
An additional extension of 60 days may also be granted for the translation of the Masterfile.
Statute of limitations on transfer pricing assessments
The statute of limitation on corporate income tax assessments is generally five years. If the tax authorities intervene with any official
action against the taxpayer in order to assess or collect tax, the relevant period is reset, without taking into account any previous lapse
of time. Nevertheless, the tax authorities’ right to assess and collect tax will cease after 10 years. The transfer pricing documentation
must be archived for 10 years.
Return disclosures/related party disclosures
Related party transactions are reported as a component of the annual corporate income tax return.
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