Transfer Pricing Documentation
Transfer Pricing Documentation in Compliance with Hungarian Requirements
Transfer Pricing Documentation in Compliance with Hungarian Requirements
Preparing transfer pricing documentation is not merely a statutory obligation but also an opportunity for companies: it allows them to present the economic and market conditions that substantiate pricing between associated enterprises. At the same time, the documentation requirement imposes a significant administrative burden on companies and, due to continuous regulatory changes, demands heightened attention.
Our services include
- Professional review of existing transfer pricing documentation;
- Preparation of new documentation in line with the applicable Hungarian legislation and the OECD Transfer Pricing Guidelines;
- Review and opinion on the company’s pricing practices, including the identification of risks;
- Recommendations to remedy any issues identified.
- Building on our many years of experience with tax authority audits, we apply a tailored approach that takes industry-specific characteristics into account.
Why is proper transfer pricing documentation important?
1. Increasing transfer pricing penalties
Failure to comply with transfer pricing documentation obligations may result in substantial fines. Following the 2022 legislative changes, the maximum default penalty for missing or incomplete documentation can reach HUF 5 million, and up to HUF 10 million in the event of recurrence.
2. More frequent and stricter audits
In our experience, the Hungarian Tax and Customs Administration (NAV) is examining transfer pricing matters with increasing frequency and depth; therefore, having appropriate documentation is not only a compliance measure but also a risk-mitigation tool.
3. Data reporting obligation
Enterprises required to prepare transfer pricing documentation must also provide transaction-level data as part of the corporate income tax return. This includes, among others, the volume of transactions with associated parties, the transfer pricing method applied, the results of database searches, and the prices used.
Why choose the tax advisory team of Central Audit Consulting?
Our goal is to ensure that our clients can face any potential tax authority audit with confidence and preparedness.
Additional Transfer Pricing Services
Market Profitability Analysis
Leveraging our proprietary databases and search strategies informed by our tax audit experience, Central Audit undertakes the determination of the arm’s length range for a given country or region, including multi-year look-back periods where appropriate. In compiling the documentation, we rely on internationally recognized databases, such as TP Catalyst and RoyaltySource.
Learn more about this service…
Preparation of the Master File
Central Audit’s services include the preparation of the group’s central transfer pricing documentation (Master File) in accordance with the applicable international guidelines and requirements.
Business focus
Audit & Assurance
Accounting Advisory
Financial Due Diligence
Company Valuation
Tax Advisory
Transfer Pricing
documentation
Special certifications
IFRS Certification
Investment Firm
Financial Institutions
Pension Fund
Sustainability
Public Interest Entities
Industry focus
Automotive Industry
Commerce
Production & Manufacturing
Real Estate Management
Not-for-profit Organizations
Services
Financial Enterprises