Advance Pricing Arrangement (APA) service of Tax Authority

This procedure provides an opportunity to agree with the Hungarian tax authority on future application of the arm’s length principle in respect of controlled transactions. The advanced pricing arrangement may be:

  • unilateral – applies to the Hungarian tax authorities and the Hungarian tax payer or
  • bilateral – applies to the two related parties and their respective tax authorities or
  • multilateral – applies to more than two foreign tax authorities and related parties.

Claims for APA must be countersigned by a tax advisor, tax expert, certified tax expert or lawyer before submission.

This is a service to pay for to the tax authority. The fees are summarised hereinafter:

  CUP method, Resales price method, Cost plus method Any other method
Unilateral reconciliation 0,5 - 5 million HUF 2 - 7 million HUF
Bilateral reconciliation 3 - 8 million HUF
Multilateral reconciliation 5 - 10 million HUF