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Transfer pricing

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

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.

Our transfer pricing experts can help to prepare your documentations professionally.

Quote on transfer pricing 

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