transzferárellenrzéseket

Transzferárellenrzéseket refers to transfer pricing regulations and audits in Hungary. Transfer pricing concerns the pricing of goods and services exchanged between related entities within a multinational group. The Hungarian tax authorities, primarily the National Tax and Customs Administration (NAV), conduct these audits to ensure that transactions between related parties are conducted at arm's length, meaning at prices that would be agreed upon by independent parties in comparable circumstances.

The objective is to prevent the artificial shifting of profits from Hungary to other jurisdictions with lower tax rates, thereby safeguarding the Hungarian tax base. Hungarian tax law, aligned with OECD guidelines, requires taxpayers to document their transfer pricing policies and demonstrate the arm's length nature of their intercompany transactions. This documentation typically includes a master file, a local file, and a country-by-country report, depending on the size and complexity of the group.

During a transzferárellenrzés, the NAV will examine the pricing methodologies used, the substance of the transactions, and the comparability of the chosen benchmarks. They may request detailed explanations and evidence from the taxpayer. If a discrepancy is found, the tax authorities can adjust the taxable income of the Hungarian entity, leading to additional corporate income tax liabilities, interest, and potential penalties. Companies operating in Hungary with cross-border transactions involving related parties must therefore pay close attention to their transfer pricing practices and maintain robust documentation to mitigate risks.