Advance Pricing Agreement (APA)

Upon request, HU TA defines in a resolution the method to be applied for determining the arm's length price in a future transaction between related parties, the facts and circumstances serving as the basis for determining the arm's length price and the arm's length price or price range, if it can be determined. In the case of a bilateral or multilateral procedure, an agreement between the Hungarian tax and customs authority and the competent foreign authority is necessary for the resolution to be effective. An advance pricing agreement procedure can be unilateral, bilateral or multilateral. If a legal regulation of a foreign state concerning income taxation is also applicable, the related party must indicate in its request its choice of unilateral, bilateral or multilateral procedure for the determining of the arm's length price. 

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