Transfer pricing services
Preparation of transfer pricing documentations
- Preparation of benchmark studies for transfer pricing purposes using databases
- Preparation of transfer pricing documentations (Master Documentation and Local Documentation)
- Review and supplementation (e.g. with benchmark studies) of documentations prepared by clients in line with the Hungarian transfer pricing regulations
Preparation of transfer pricing documentations and policies
- Submission of country-by-country reports (CbCR)
- Development and review of an internal transfer pricing policy
- Review of the reporting obligation under the DAC6 directive from a transfer pricing perspective and preparation of reports (MDR)
Cooperation during transfer pricing audits
- Support and consulting in transfer pricing matters during audits by the Hungarian Tax and Customs Authority
Consulting in transfer pricing matters
- Transfer pricing related risk assessment, recommendations for the efficient management of risks and for the development of the most appropriate business model (introduction of a new group structure, restructuring, cross-border transactions, etc.)
- Transfer pricing consultation to address the effects of the global COVID-19 pandemic within the company group
- Support for domestic companies during transfer pricing negotiations within their company group and pricing-related consulting
- Support in the selection of the most appropriate transfer pricing method and review of the methods used in previous years
- Consulting in relation to OECD-BEPS and EU-level international transfer pricing regulations (CbC reporting, functional and risk analysis, hard-to-value intangible assets, cross-border restructuring of activities, etc.)
APA
- Preparation of APA requests and cooperation during discussions with the Hungarian Tax and Customs Authority
