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Transfer pricing services

A substantial part of world trading is made up of so-called related party transactions between members of company groups.
However, market conditions may not necessarily apply at all times between non-independent parties and the transfer pricing rules introduced and developed continuously at domestic and international (OECD-BEPS, EU) level serve the purpose of preventing the shifting of incomes among countries by way of diverging intra-group product and service prices from market prices.

Why should you engage us to fulfil transfer pricing tasks and solve transfer pricing problems?

Hungarian members of company groups must keep in mind that transfer pricing is not only an integral part of their everyday administration activities but also plays an important role in the development, operation and the transformation of their business models. Transfer price audits (in terms of the compliance of documentations and related party pricing) have been a focus area of the Hungarian Tax and Customs Authority for years. OECD–BEPS actions relating to transfer pricing are intended to achieve greater transparency by introducing new, more detailed rules and processes thereby providing a means for tax authorities for making transfer price audits more efficient. But you do not have to face this complex task alone; our qualified and motivated experts can help your work with our transfer pricing services.

Transfer pricing services

Documentation

  • Preparation of documentations (independent, consolidated or common documentations)
  • Review and supplementation of documentations in line with domestic requirements

Transfer price audit

  • Support and consulting in transfer pricing matters during audits of the Hungarian Tax and Customs Authority

Consulting

  • Transfer pricing related risk assessment, recommendations for the efficient management of risks and for the development of the most appropriate business model (introduction of new group structure, restructuring, cross-border transactions etc.)
  • Transfer pricing policy development
  • Support in relation to OECD-BEPS and international EU transfer pricing regulations with special regard to CbC reports

APA

  • Preparation of applications, cooperation during the reconciliation with the Hungarian Tax and Customs Authority

Do you have any question?

Don't hesitate to contact us!

Helga Kiss, tax director, RSM Hungary

Helga Kiss

Director, Tax services

János Karczub

Manager, Tax Services

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