The prices applied in transactions between related parties are referred to as transfer prices. In Hungary, since 1992, in accordance with the provisions of the Corporate Tax Act and aligned with the OECD Transfer Pricing Guidelines, the arm’s length principle must be applied when determining transfer prices. Accordingly, taxpayers that do not qualify as small businesses must prepare transfer pricing documentation for contracts and transactions with related parties by the deadline for filing the corporate tax return, provided that a performance took place during the tax year in connection with these transactions.

Hungarian transfer pricing regulations are continuously evolving, with increasingly strict requirements, particularly due to the growing frequency of tax authority audits.

For companies, it is essential to continuously review and update their transfer pricing compliance, as the lack of documentation or improper preparation can lead to significant tax risks and penalties.

BDO Transfer Pricing Advisory Services

The transfer pricing expert team of BDO Hungary provides full support for your company in the following areas:

• Assessment and examination of transfer pricing documentation obligations;

• Planning, reviewing, and establishing transfer prices;

• Preparation of transfer pricing maps;

• Identification of related parties, determination of company size;

• Notification of related parties;

• Review of contracts between related parties;

• Review, supplementation, and preparation of the Master File and Local File (transfer pricing documentation);

• Examination of ongoing transactions between related parties;

• Preparation of benchmark analyses using international databases;

• Establishment of an arm’s length price range;

• Preparation for Advance Pricing Agreements (APA) and participation in the procedure;

• Support in procedures with the tax authority;

• Planning the pricing of intangible assets;

• Pricing of financial transactions;

• Proposing the development of the group structure;

• Preparation of value chain (VCA – Value Chain Analysis) and functional analyses;

• Preparation of country-by-country reports (CbCR), completion and submission of related forms.

International Transfer Pricing Advisory and Network

BDO Hungary, as part of the global BDO network, is one of the leading transfer pricing advisory centers in the region, with expertise in the transfer pricing regulations of Central and Eastern European countries as well.
Through our Budapest regional center, we have extensive experience in preparing international transfer pricing documentation and benchmark analyses.

With our partner offices present in more than 160 countries worldwide, we ensure fast and efficient handling of inter-country transfer pricing coordination. To guarantee global transfer pricing compliance, we continuously monitor the OECD and local tax authorities' regulations to enable our clients to always apply up-to-date and lawful transfer pricing strategies.

If you require transfer pricing advisory, documentation preparation, or representation before the tax authorities, our experts are at your disposal at tax@bdo.hu.