Transfer pricing

Related-party transactions are subject to special transfer pricing rules, as well as record-keeping and reporting obligations relating to transfer pricing.

Market conditions may not necessarily apply at all times between non-independent parties, and the transfer pricing rules introduced at domestic and international (OECD-BEPS and EU) level serve the purpose of preventing the shifting of incomes among countries.

The relationship between the intra-group prices of goods and services and the market price can be examined based on the mandatory transfer pricing documents required by the regulation.

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 and operation of their business models.

Transfer pricing audits (in terms of the compliance of documentations and related-party pricing) are among the focus areas of the Hungarian Tax and Customs Authority. OECD-BEPS regulations relating to transfer pricing are intended to achieve greater transparency in this regard, thereby providing a means for tax authorities for making transfer pricing audits more efficient.

Our qualified and motivated experts can help you in tasks relating to transfer pricing documentations by providing transfer pricing services.

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

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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