Hungary: Transfer pricing documentation requirements | KPMG | US

Hungary: Transfer pricing documentation requirements updated, including arm’s length pricing

Hungary: Transfer pricing documentation requirements

New measures concerning transfer pricing documentation requirements—and specifically arm’s length pricing—were included in a decree, expected to be effective in November 2017.

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The decree was issued 18 October 2017 and is to be effective 30 days following its promulgation. 

The new transfer pricing documentation requirements generally are in line with the recommendations from the OECD and the European Union, and require a Master file and a Local file. Also, the new rules set forth:

  • Deadlines for complying with the new documentation requirements
  • Clarifications when modifications can be made to the transfer pricing documentation records
  • Rules for making comparable data searchable
  • Measures that extend the transfer pricing requirements to transactions between a foreign entity and its Hungarian permanent establishment
  • Conditions and methodologies for determining the arm’s length price (and modifications to applying the arm’s length price to low value-added intra-group services)

 

Read an October 2017 report [PDF 185 KB] prepared by the KPMG member firm in Hungary

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