Manager, Tax Services
János Karczub is an economist and a tax consultant. He has been working as an expert in the field of taxation for more than 10 years, as a project manager and participant he has gained experience primarily in consulting work related to taxation and transfer pricing issues concerning affiliated parties of multinational companies.
He has extensive experience in the preparation of transfer pricing documentation for domestic and international companies, transfer pricing consulting and tax audits. Owing to his experience in corporate finance and analysis in the financial sector, he also has significant expertise in the area of intercompany loans and financing structures.
He has joined RSM Hungary as a tax advisor for more than seven years.
As part of the transfer pricing related tasks, the obligation to file a country-by-country report (CbCR) and notification to the tax authority must be fulfilled by 31 December 2024 for fiscal years corresponding to the calendar year.
Read moreIn 2022, significant changes were made to transfer pricing and the preparation of transfer pricing documentation, with a multiplication of the fine and the introduction of a transfer pricing data reporting obligation. Please note that non-compliance with changes entered into force for the 2023 tax year could result in the imposition of multiple default penalties. Based on the experience of the past year, businesses are increasingly likely to face direct transfer pricing audits on transactions with their related parties.
Read moreThis year was a turning point for companies in the field of transfer pricing, as they were required to provide information on the determination of the arm\'s length price in their corporate income tax returns. We have collected the main issues and topics that have caused the most problems for companies when preparing their 2023 transfer pricing data reporting.
Read moreThe decree containing the detailed rules for transfer pricing has been issued without substantial changes*, the draft version of which and the scope of the future transfer pricing reporting obligation were previously presented in our blog. Starting from 2023, taxpayers will be subject to a new reporting obligation regarding their transfer pricing reports, as information on related-party transactions will need to be included as a new element in corporate income tax returns as well. In addition to this new administrative obligation, the threshold for preparing reports has also changed. The most important changes and tasks for companies following the entry into force of the final transfer pricing decree are presented below.
Read moreA draft amendment to the transfer pricing decree is now available, detailing the data that will need to be included in the corporate income tax return from 2023 onwards in relation to transfer pricing documentation in Hungary. In addition to the new administrative task, the documentation threshold value is expected to change and the number of transactions to be documented may be reduced.
Read moreA two-and-a-half-fold increase in default fines, a new transfer pricing reporting obligation relating to corporate income tax returns, and changes in the rules pertaining to tax base adjustments. Bill T/360 is expected to have an impact on several aspects of the transfer pricing rules pertaining to related parties, and we are likely to see stricter regulations in this regard.
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