How we can support you

We have created a set of transfer pricing services to assist you in achieving your strategic global business objectives. Our transfer pricing group will use the experience and expertise they have acquired to help you turn a problem into a solution.

Documentation

• Preparation of consistent documentation for all types of inter-company transaction, in compliance with local regulations. This includes the preparation of country-specific risk assessment and country-specific documentation when necessary.
• Advice regarding transfer pricing documentation prepared by the client, in order to ensure compliance with local requirements and consistent disclosure of information.
• Where companies hold Group Documentation / Master File centrally we can localise that for a Hungarian tax purposes.
• Supply of information on developments in local and foreign regulations, and other issues.

Advance Pricing Agreements

As of 1 January 2007 it is possible to apply for advance pricing agreements with tax authorities which can provide certainty with respect to pricing methodology on related party transactions. We can assist both the application and negotiation process.

Dispute resolution

• Assistance in administrative and judicial procedures on transfer pricing related matters
• Assistance in international disputes on transfer pricing issues (e.g. mutual agreement procedures)

Planning

Transfer pricing planning identifies opportunities to:

• Implement supportable transfer pricing policy
• Mitigate the incidence of disputes with tax authorities
• Mitigate the possibilities of double taxation of profit allocation between related parties