Transfer pricing: A comprehensive compliance guide for the Czech Republic, Hungary, Poland and Slovakia

Transfer pricing has become a critical issue for multinational companies operating in the Visegrád Group (V4), which includes the Czech Republic, Hungary, Poland, and Slovakia. Ecovis experts from these countries have therefore developed a comprehensive guide to help companies correctly implement the requirements.

The alliance shares a rich historical and economic background, which has created close business ties and made the region an attractive destination for foreign investment. Nevertheless, the V4 maintain distinct legislative and regulatory environments, particularly in the field of transfer pricing, creating both opportunities and significant compliance challenges for companies.

OECD guidelines on transfer pricing in national legislation

The V4 countries, as members of the OECD, have incorporated the OECD transfer pricing guidelines and the BEPS (Base Erosion and Profit Shifting) framework into their national legislation. However, each member state interprets and applies the soft law differently, leading to a diverse and sometimes fragmented regulatory landscape.

Over the past few years, transfer pricing has attracted heightened attention from tax authorities across the region. The post-COVID era has seen a wave of legislative updates and stricter enforcement, with authorities leveraging transfer pricing audits as a key tool to address potential non-compliance. As a result, tax advisors must navigate not only national documentation requirements – such as Local Files and Country-by-Country (CbC) notifications – but also the small details of each jurisdiction’s approach to compliance, penalties, and audit procedures.

The complexity emerges further in documentation thresholds, language requirements, penalty regimes, and the use of databases for benchmarking. For example, the criteria for related-party definitions, the scope of documentation, and the treatment of low-value transactions vary significantly. Moreover, the increasing digitalisation of tax administration and the introduction of new reporting forms have placed additional pressure on taxpayers to maintain robust and up-to-date transfer pricing documentation.

We provide you with support in implementing the complex transfer pricing process in the Czech Republic, Hungary, Poland and Slovakia.

Branislav Laurinc, Tax advisor, ECOVIS LA Partners Tax, Bratislava, Slovak Republic

What companies should do now

Given the dynamic regulatory environment and the growing scrutiny from tax authorities, companies operating in the V4 must be proactive in managing their transfer pricing risks. Accurate and country-specific documentation with a thorough understanding of local regulations is essential to avoid costly penalties and ensure compliance.

As the region continues to evolve its approach to transfer pricing, staying informed of legislative changes and audit trends will be crucial for businesses seeking to navigate the complexities of the V4 market.

For further information please contact:

Dávid Szabó, Tax advisor, ECOVIS Hungary Tax, Budapest, Hungary
Email: david.szabo@ecovis.hu

Simona Fialova, Partner, ECOVIS FACTA a.s., Prague, Czech Republic
Email: simona.fialova@ecovis.cz

Branislav Laurinc, Tax advisor, ECOVIS LA Partners Tax, Bratislava, Slovak Republic
Email: branislav.laurinc@ecovis.sk

Agata Wleklinska, Tax advisor, ECOVIS LEGAL POLAND, Warsaw, Poland
Email: agata.wleklinska@ecovis.pl