Transfer pricing documentation

As part of this service we perform the followings:

  • Compilation of transfer pricing documentation;
  • Transfer pricing consultancy;
  • Administration of applications for advance pricing agreements (APA) concerning the assessment of arm’s length price .

Nowadays the tax authorities pay outstanding attention to inspecting whether the legal regulations pertaining to the prices applied between related companies are complied with. The effective legal regulations require the related companies to maintain transfer pricing documentation concerning the prices applied between them (transfer prices) for their controlled transactions, which must comply with the prescribed requirements in terms of form and content. The legal regulations effective since 2010 amended the definition of related companies. The amendments concern not only the international, but also the Hungarian companies, thus the development of the transfer price documentation is also a requirement towards the latter.

Exploiting the experience gained in recent years our company can also provide your company with expert assistance in the development of the documentation tailored to your company, ensuring that it complies with the requirements both in terms of content and form. The transfer pricing documentation is prepared with the assistance of the software used and recognised by the National Tax and Customs Agency, which provides us with the facility to serve our customers with a huge database background.

If a specific transaction is of high risk, it is possible that the tax authority – upon request – establishes in a resolution the method to be applied upon defining the arm’s length price enforceable in the transaction concerned, the facts and circumstances underlying the assessment, and – if it can be determined – the arm’s length price and price range (APA – advance pricing agreement). Prior to submitting the application the client may initiate preliminary consultancy proceeding, where the applicant and the acting authority conduct advance consultations  on the conditions, scheduling and method of conducting the procedure and the potential ways of cooperation.