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János Karczub

Senior manager, Tax Services

János Karczub is an economist and a tax consultant. He has been working as an expert in the field of taxation for more than 10 years, as a project manager and participant he has gained experience primarily in consulting work related to taxation and transfer pricing issues concerning affiliated parties of multinational companies.
He has extensive experience in the preparation of transfer pricing documentation for domestic and international companies, transfer pricing consulting and tax audits. Owing to his experience in corporate finance and analysis in the financial sector, he also has significant expertise in the area of intercompany loans and financing structures.

He has joined RSM Hungary as a tax advisor for more than seven years.

Phone+36 1 886 3700, +36 1 886 3701
János Karczub's topics
János Karczub
János Karczub

Transfer Pricing Adjustment 2025: Avoid Tax Pitfalls

As the 2025 deadline for preparing transfer pricing documentation approaches for companies with a calendar fiscal year, the issue of subsequent transfer pricing adjustments is once again coming into focus. In recent years, in Hungary significant tightening measures have been introduced which all companies should take into account to avoid tax risks.

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János Karczub
János Karczub

Transfer pricing 2024 – Record number of direct transfer pricing audits

In 2022, significant changes were made to transfer pricing and the preparation of transfer pricing documentation, with a multiplication of the fine and the introduction of a transfer pricing data reporting obligation. Please note that non-compliance with changes entered into force for the 2023 tax year could result in the imposition of multiple default penalties. Based on the experience of the past year, businesses are increasingly likely to face direct transfer pricing audits on transactions with their related parties.

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János Karczub

Transfer pricing data reporting 2023: experience and obligations

This year was a turning point for companies in the field of transfer pricing, as they were required to provide information on the determination of the arm\'s length price in their corporate income tax returns. We have collected the main issues and topics that have caused the most problems for companies when preparing their 2023 transfer pricing data reporting.

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János Karczub

Decree containing detailed transfer pricing rules issued

The decree containing the detailed rules for transfer pricing has been issued without substantial changes*, the draft version of which and the scope of the future transfer pricing reporting obligation were previously presented in our blog. Starting from 2023, taxpayers will be subject to a new reporting obligation regarding their transfer pricing reports, as information on related-party transactions will need to be included as a new element in corporate income tax returns as well. In addition to this new administrative obligation, the threshold for preparing reports has also changed. The most important changes and tasks for companies following the entry into force of the final transfer pricing decree are presented below.

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