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Briefly about transfer pricing
When preparing transfer pricing documentation, the parties considered as a company group must be identified, the related party transactions occurring during the year must be specified, and if their market value reaches the prescribed threshold (above HUF 100m from 1 January 2023, HUF 50m before), the market price must be supported by formal documentation. This is called transfer pricing documentation.
This documentation is used by the taxpayer to show that the prices (transfer prices) used in its transactions with its related parties are arm's length (or not arm's length and then includes a calculation to adjust the tax base). Thus, transfer pricing records/documentation is an analysis that details each transaction to be documented, examines and tests the prices used in the transactions using the most appropriate method and evidence. As part of the record, the circumstances of the transactions, the taxpayer company and its role in the group and the industry, and an overview of the group as a whole are presented.
Important: From 2023, data must be provided in the VAT return!
Due to new legislation changes, from 2023 onwards, certain items in the transfer pricing documentation will have to be reported in the corporate tax return, so it is essential that companies have their transfer pricing documentation completed and in order in time!
Who is required to provide the information?
Enterprises with more than 50 employees or more than €10 million turnover or balance sheet total on the last day of the tax year, in terms of the combined indicators of the group of companies.
What are the consequences if no transfer pricing records are kept?
Failure to keep a transfer pricing register can result in a default fine of HUF 5 million. If it is not completed in the following year and a repeat offence is committed, a default fine of HUF 10 million per register is likely to be imposed. Read our technical article on this here: Tightening transfer pricing record-keeping rules may prepare businesses for NAV audits!
Why is it worth working with us?
We have years of professional experience,
We work with the highest level of expertise and precision,
We take responsibility for our work,
We provide a fast, efficient and reliable service, ensuring you have peace of mind with your transfer pricing documentation.
Don't wait any longer, contact us for a personalised quote and enjoy peace of mind in your transfer pricing documentation for the future!
