Slovenia Transfer Pricing Documentation Requirements
Slovenia requires transfer pricing documentation, including a Master File, from every company that transacts with related parties, regardless of the value of those transactions. The documentation is produced within 30 days of a request, and documentation must be archived for ten years.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Every company with related-party transactions | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | EN / SL / DE | Yes (up to EUR 30,000; up to EUR 40,000 for responsible persons) |
TP documentation Required | Every company with domestic or foreign related-party transactions, irrespective of value | By tax return filing date | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | SL | Yes (up to EUR 30,000) |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Slovenia deadline
Enter your entity’s fiscal year-end to return your exact Slovenia preparation or filing date. Available without registration.
Scope of the documentation obligation
Slovenia applies its documentation requirement without a value threshold. Every company that transacts with related parties, whether domestic or foreign, must maintain transfer pricing documentation, and the preparation of a Master File is required of every company with related-party transactions. The documentation is produced within 30 days of a request. There is no de minimis level beneath which the obligation falls away.
Distinctive features of the Slovenian regime
The defining feature of the Slovenian regime is the breadth of the obligation combined with personal penalty exposure. Because there is no value threshold, even small related-party dealings bring a company within the documentation duty. The penalty for failing to submit documentation in the prescribed manner or within the deadline reaches EUR 30,000 for the legal entity, with a separate penalty of up to EUR 40,000 capable of falling on the responsible persons of the entity, so the consequences extend to individuals rather than resting on the company alone. Slovenia provides a safe harbour for related-party loans, under which the intercompany interest rate is set administratively as an interbank rate plus a mark-up geared to the credit rating and term.
Benchmarking and comparables
Pan-European benchmarks are acceptable. There are no specific rules on single-year versus multi-year testing, and because the tax authority usually reviews several periods a multi-year analysis, typically over three years, is accepted in practice. A benchmarking study may be updated by refreshing the financials, with no requirement for a new study each year, although it must be updated at least every three years. The general limitation period is five years, reset by any official action and ceasing after ten years, with documentation archived for ten years.
Frequently asked questions
Is there a minimum transaction size below which Slovenia requires no documentation?
No. The obligation applies to every company with domestic or foreign related-party transactions, irrespective of the value of those transactions, including the preparation of a Master File.
Can individuals be penalised under the Slovenian regime?
Yes. Alongside a penalty of up to EUR 30,000 for the legal entity, a separate penalty of up to EUR 40,000 can fall on the responsible persons of the entity for documentation failures.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.