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.
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:
Read an October 2017 report [PDF 185 KB] prepared by the KPMG member firm in Hungary
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.