Transfer pricing services

Transfer pricing services

We recommend our transfer pricing documentation service to companies that have active business relationships with their related parties (e.g. through the delivery of goods or services, or through financial or other transactions). Typically management fees are usually subject to transfer pricing documentation.

What are your benefits?

The tax authority checks as a priority of its tax inspections whether a business has established the transfer prices of transactions with its related parties correctly. If a business has prepared transfer pricing documentation in line with the applicable regulations, it is the tax authority’s burden to prove that the applied prices are different from the arm’s length prices.

The tax authority is authorised to charge a default penalty if the business does not have transfer pricing documentation. Moreover, the content of the documentation is also important as the documentation determines whether the tax base needs to be adjusted with regard to the prices applied between related parties. If the company does not have proper transfer pricing documentation, then it will be required to prove during the inspection that the applied prices were correct. Moreover, the tax authority also has the right to impose a penalty of as much as HUF 5 million per contract for any missing documentation.

Services

• Local documentation, Master File, CBCR report

If your company does not yet have local documentation or a Master File, we will prepare a legally compliant record for the affiliated companies or, if necessary, for the entire group of companies after requesting the necessary documents. In order to determine the market price, we also use internationally recognized databases that are based on reliable settlement prices that can be properly substantiated by the tax authority. Our office also provides assistance with CBCR reports.

• Corporate tax reporting

We provide assistance with the content of the ATP-01 and ATP-KV forms to be filled in as part of corporate tax.

• Review of transfer pricing documentation

If your company already has transfer pricing documentation, but is uncertain whether the data would stand the test of an official audit, it is worth having it checked by an external expert. We are happy to comment on the prepared transfer pricing documentation and, if necessary, make additional or modification proposals. Checking the documentation can also be considered if you want to be sure that the methods taken over from the parent company meet the stricter requirements in Hungary. During the audit, we prepare a detailed report in which we identify potential risks and provide solutions to improve them.

• Transfer Pricing Advisory

If you are unsure about what price to set or want to check whether the price you have set meets market expectations, please contact our staff. This can also be important in the case of small businesses, as companies with business relationships must always apply the appropriate settlement price, regardless of whether there is an obligation to record transfer pricing or not. If the market price has been determined incorrectly, the necessary corrections must be made. Within the framework of our advisory services, we also undertake the modification of tax returns due to transfer pricing adjustments.

• Professional support in the Advance Price Determination Procedure (APA)

In order to minimize tax risks, we undertake to advise on APA procedures, or even to carry out the entire implementation. Our colleagues provide assistance in compiling and submitting the inspection request, answering official questions, and coordinating personal consultations.

• Representation before the tax authority

We provide you with professional support in the case of transfer pricing control, if required. After reviewing the documents, we undertake to conduct professional consultations.