Hungary transfer pricing documentation guide
March 01, 2008
Denes Szabo, tax partner at Ernst & Young in Budapest, outlines the transfer pricing documentation framework in Hungary
The Hungarian transfer pricing legislation is modeled on the OECD Transfer Pricing Guidelines. Transfer pricing rules apply to related-party transactions, where the relationship is determined on the basis of either direct or indirect majority control. In addition to possession of the majority of voting rights, majority control can also be secured by virtue of rights for the appointment or removal of the majority of the directors or supervisory board members. The term parties for transfer pricing purposes also includes resident and non-resident entities as well as branches and permanent establishments.
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