Transfer Pricing Documentation
Preparation of the Master File
Transfer Pricing Documentation – Preparation of the Master File
For multinational enterprise groups, the Master File is a mandatory component designed to provide a comprehensive overview of the group’s global operations, transfer pricing strategy, and value chain. This document is based on the OECD Transfer Pricing Guidelines as well as Hungarian domestic regulations, and serves as a complementary element to the Local File.
As part of our service, we undertake the full preparation of the Master File, including:
- A presentation of the group’s structure, activities, and operations;
- A description of key value-creating activities and intangible assets;
- An overview of the financial and financing structure;
- A detailed presentation of the group-level transfer pricing policy and intragroup agreements;
- Processing and interpretation of the annual consolidated financial information.
Why is a well-prepared Master File important?
It provides the authorities with a clear and coherent picture of the group’s operations and is an essential tool for minimising transfer pricing risks. A properly documented Master File can significantly support the group in defending its pricing and structures during any potential tax audit.
Why choose the tax advisory team of Central Audit Consulting?
Our expert team supports clients with up-to-date knowledge and practical experience to ensure the efficient and legally compliant fulfilment of transfer pricing documentation obligations. Our goal is to help clients face any potential tax authority audit with confidence and preparedness.
Additional Transfer Pricing Services
Transfer Pricing Documentation in Compliance with Hungarian Requirements
Our specialists deliver tangible value, ensuring that our advisory work plays a strategic and productive role in today’s corporate governance environment. We identify areas for improvement and recommend tools that support the achievement of your organisational goals and contribute positively to your company’s successful operation.
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Market Profitability Analysis
Using our available databases and search strategies rooted in our tax audit experience, Central Audit determines 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 recognised databases such as TP Catalyst and Royalty Source.
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Business focus
Audit & Assurance
Accounting Advisory
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Tax Advisory
Transfer Pricing
documentation
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