Transfer pricing / Transzfer árak

G. Erdős: Hungary Introduces an Annual Transfer Pricing Data Reporting System, International Transfer Pricing Journal, 2023 (Volume 30), No. 3

The article describes the Hungarian transfer pricing data reporting rules effective as of 2023. The new rules require detailed annual reporting on transactions with related parties as a part of the corporate income tax return. The expressed goal of the new reporting obligation is to assist the tax authorities in their risk assessment and audit subject selection exercise. The new requirement is also supposed to encourage taxpayers to prepare their transfer pricing documentations in time, otherwise, they will not be able to fulfil their reporting obligations. The article analyses the scope of the new reporting obligations including transaction types, methods, indicators and range. It also gives an update on the current focus of state tax audits and the most frequent assessments.

Erdős, G.: Az értékteremtés, transzferárak, csoportos adóalanyiság (Value Creation, Transfer Pricing, and Group Taxation) Ladó László Emlékkonferencia kötet, Lukács, J. (szerk.), BCE, Budapest (2020), pp19-31 ISBN: 978-963-503-832-9

Abstract: Hungary introduced new corporate group taxation rules as of 2019. One of the designated goal of the new rules is to ease up transfer pricing documentation requirements for intra-group transactions. The paper explains the new regime and its effect on transfer pricing.

Erdős, G.: A kapcsoltság megítélése és a transzferárazás alkalmazása (Related Parties in Transfer Pricing) SZAKma 2019 7-8 (2019), 41-43. Számvitel Adó Könyvvizsgálat: SZAKma 1419-6956

Abstract: Transfer pricing legislation has a long history both internationally and in Hungary yet, in some simple cases, the determination whether parties are related still proves to be difficult. The paper analyzes four situations, namely, majority influence if voting rights do not follow ownership rights, the aggregation of participation of close relatives, interpretations of same management, and the calculation of indirect interest. The common theme in these situations is that neither the legislation nor the legal practice gives unambiguous rules and their calculation.

Czoboly, G., Erdős, G.: Hungarian Group Taxation to Counterbalance the Tightening Transfer Pricing Documentation Rules, International Transfer Pricing Journal (ITPJ), 2019 (vol.26) No. 3 209-2014, ISSN: 1385-3074

Abstract: A new corporate tax grouping concept was introduced in Hungary as of 2019 with the aim of easing transfer pricing documentation burdens. This article highlights some of the peculiar features of the new Hungarian group taxation rules and gives an overview of some of the practical aspects of the transfer pricing documentation rules implemented in Hungarian legislation as of 2018. The analysis focuses on the interrelationships between these transfer pricing rules and the new group taxation rules, and highlights their shortcomings and the opportunities they offer.