Radical changes are coming in transfer pricing requirements

OECD’s new discussion draft on transfer pricing documentation may bring radical changes in the everyday work of companies. The planned regulation is even stricter than the current Hungarian practice. According to EY tax partner Zoltán Lipták, the new regulation may enter into force already early next year. OECD’s proposed new guidelines include country-by-country reporting for multinational companies to the tax authorities, making information on all the companies in a group available to the tax authorities in each country. In the current situation it is important for companies to survey their internal transfer pricing practices, to revise the transfer pricing strategies item by item, together with the documentation of those legal entities which are expected to receive attention from the tax authorities, and to prepare for the imminent changes.