Independent transfer pricing advisory
Transfer pricing represents a crucial aspect of direct taxation and is currently subject to tax audits. The Income Tax Act requires associated parties to adhere to the Arm´s Length Principle in all forms of both domestic and cross-border controlled transactions.
Transfer pricing requires a multidisciplinary approach that should align with the recommended OECD standards, such asOECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations (2022) or original document).
Due to the existing legal uncertainty and the lack of detailed recommended procedures (methodological guidelines) for determining transfer prices, taxpayers frequently encounter the risk of incorrect pricing, which is mainly associated with potential increases in the tax base and resulting penalties.
Services
As part of our professional services, we provide expert opinions and recommendations on transfer pricing in line with Slovak legislation and OECD guidelines. Our methodology integrates established transfer pricing standards and practices with cutting-edge academic research, in which we are frequently directly involved. Given the complexity of the matter, we will provide you with a tailored quotation and a proposed solution that fully takes into account your specific needs and the unique characteristics of your business.
About us
doc. Ing. Michal Ištok, PhD.
He has been specializing in transfer pricing and international tax planning for over a decade through his academic research, the findings of which he actively applies in professional practice. In 2024, he earned his habilitation at the Faculty of Business, Brno University of Technology, with a thesis focused on Transfer Pricing of Credit and Loans in the Czech and Slovak Republic. He regularly contributes as an author or co-author to scientific and professional journals and takes part in international academic and industry conferences. He is also a member of research teams on several domestic and international scientific projects. His professional engagement includes participation in expert events organized by the WU Transfer Pricing Center in Vienna (Institute for Austrian and International Tax Law).
doc. Ing. Veronika Solilová, Ph.D.
external consultant
Veronika Solilová graduated at the Faculty of Business and Economics of Mendel University in Brno, the doctoral study programme in Finance in 2010 with the topic of transfer pricing, and in 2021 she was attained as Assoc. Prof. in Finance at the Prague University of Economics and Business. Currently she has been working at the Faculty of Finance and Accounting of the Prague University of Economics and Business, Department of Public Finance. Her expertise is transfer pricing, worldwide corporate taxation issues, environmental taxes, fiscal policies, coordination and fight against the tax evasion/tax fraud. In 2021 was also appointed as an expert for transfer pricing by the Ministry of Justice. She is author and co-author of many professional and scientific articles, monographs published by Wolters Kluwer, Springer, IBFD publishing houses and scientific journals.
Publications
Further publications are available on ResearchGateon the project website of TAČR and in University Library of Matej Bel University..
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