Transzferárnyilvántartás

Transzferárnyilvántartás, often translated as transfer pricing documentation, refers to the records and analyses that multinational enterprises (MNEs) must maintain to demonstrate that their intercompany transactions are conducted at arm's length. This means that the prices charged between related entities within an MNE group should be the same as if those transactions were conducted between independent parties. Tax authorities require this documentation to ensure that profits are not artificially shifted to lower-tax jurisdictions, thereby eroding the tax base of higher-tax countries.

The core principle of transzferárnyilvántartás is to justify the pricing of goods, services, intangibles, and financing provided between related companies. This typically involves preparing a Master File, which provides a high-level overview of the MNE's global business, its value chain, and its transfer pricing policies. Additionally, Local Files are required for each jurisdiction where the MNE operates, detailing specific intercompany transactions within that country and applying the chosen transfer pricing method. Common methods include the Comparable Uncontrolled Price (CUP) method, the Resale Price Method (RPM), the Cost Plus Method (CPM), the Transactional Net Margin Method (TNMM), and the Profit Split Method (PSM).

The preparation of comprehensive transzferárnyilvántartás is crucial for MNEs to mitigate the risk of transfer pricing adjustments and potential double taxation. These documentation requirements have become increasingly stringent globally, driven by initiatives like the OECD's Base Erosion and Profit Shifting (BEPS) project. Failure to provide adequate documentation can lead to significant penalties and disputes with tax authorities.