Transfer pricing investigations

Nowadays the Hungarian Tax Authority places more emphasize on the review of controlled intercompany transactions. As they are getting more educated and experiences on this field, they pay more and more attention on the content of documentations.

Tax authority has access to AMADEUS database, which allows them to check arm’s length price.

After the due date of corporation tax return, tax authority may

  • ask the company to show its transfer pricing documentations within 3 working days for tax revision purposes, and
  • check if the company has reported the its related parties to the tax authority at the beginning of controlled transactions, and also at the termination of contract.

If the company is unable to provide the documents, they may be fined for maximum 2 million HUF default penalty per transaction.