The tax authority has started the control of transfer price data services

By: Trademagazin Date: 2023. 11. 14. 11:14

The professional and accurate preparation of transfer pricing documentation as well as the tax authority’s inspections have been a challenge for taxpayers until now, but from this year, the relevant legislation has been tightened and as a result the fines for non-compliance have also increased significantly, in addition, transfer pricing documentation is also checked more strictly by the NAV.

As a new element, companies involved in transfer pricing must already record the market price for linked transactions and the related additional information in the annual corporate tax return. Experience shows that after checking the data services, the tax authority launched targeted audits at companies with affiliated enterprises, during which tax audits were also carried out in many cases, currently typically for the business year 2021 – points out Tamás Kiss, SALDO Zrt director of its consulting business.

The rules regarding the registration of transactions between affiliated enterprises affect approximately 15-20 thousand companies in Hungary. When starting the tax authorities’ investigations, the tax inspectors not only scrutinize the transfer price documentation, but also ask you to fill out a 17-question questionnaire, with the help of which they determine whether the documentation covers all transactions of the affiliated companies. The background of the ever-increasing inspections may lie in the transfer price data provision introduced for this year, which the affected taxpayers had to prepare for the 2022 business year for the first time, but it can also be inferred from the related transactions carried out in previous years.