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 five years.
A draft amendment to the transfer pricing decree is now available, detailing the data that will need to be included in the corporate income tax return from 2023 onwards in relation to transfer pricing documentation. In addition to the new administrative task, the documentation threshold value is expected to change and the number of transactions to be documented may be reduced.
A two-and-a-half-fold increase in default fines, a new transfer pricing reporting obligation relating to corporate income tax returns, and changes in the rules pertaining to tax base adjustments. Bill T/360 is expected to have an impact on several aspects of the transfer pricing rules pertaining to related parties, and we are likely to see stricter regulations in this regard.
The OECD\'s guideline on the impact of the COVID-19 virus situation on transfer pricing provides guidance to taxpayers and tax authorities on transfer pricing issues.
Companies that use a business year identical with the calendar year must prepare their transfer pricing documentation by the end of May 2021, the latest.