• Skip to main content
  • Skip to primary sidebar
  • Skip to footer

Email: accace@accace.com

Contact us
Sign up for news
  • Locations
  • Websites
    • Global (English)
    • Global (German)
    • Czech Republic
    • Germany
    • Hungary
    • Poland
    • Romania
    • Russia
    • Slovakia
    • South Africa
    • Ukraine
    • United States of America (USA)
  • eShop

Accace - Outsourcing and advisory services

  • Services
    • OUTSOURCING
    • Accounting and reporting
    • Accounting online portal
    • Payroll and HR administration
    • Payroll and HR online portal
    • Time and attendance online portal
    • ADVISORY
    • Tax advisory
    • Transaction advisory
    • Legal advisory
    • Corporate and secretarial
    • Advisory online portal
    • MARKET ENTRY SUPPORT
  • COVID-19
  • About us
    • Who we are
    • Case studies
    • Meet our key People
    • Partner with us
    • Corporate Social Responsibility
  • Careers
    • Open positions
    • Who we are
    • Our values
    • Success stories
    • How we care
    • How we act
    • We volunteer
  • Newsroom
  • Events
  • Locations

Stand-alone Transfer Pricing Documentation in Hungary | News Flash

25 Nov 2015

Download Download PDF!

 

 

Stand-alone Transfer Pricing Documentation in Hungary

Our previous newsletters included the rules of preparing transfer pricing documentation in general. This week we will focus on the stand-alone transfer pricing documentation.

Compulsory elements of the stand-alone transfer pricing documentation

The stand-alone transfer pricing documentation, only including the transactions of the companies concerned, is the most frequently used documentation type prepared by the Hungarian taxpayers. The compulsory elements of the stand-alone documentation are detailed by the Hungarian Decree no. 22/2009 (X.16.) on transfer pricing documentation requirements.

In the interest of clarity, in our summary we group the compulsory elements of the stand-alone transfer pricing documentation into 6 groups, which are as follows: company analysis, description of the contract, functional analysis, industry analysis, economic analysis and financial analysis.

Content of each part of the documentation

1.     Company analysis
The purpose of the company analysis is the presentation of the associated companies (name, registered seat, tax number), and the presentation of the value-added transactions performed between the related parties.

2.     Description of the contract
Description of the contract should include the temporal elements of the contract (date of contract, term of the contract in time), related amendments. Furthermore, the characteristics of the product or service as subject matter of the contract, terms and conditions of the performance, the elements and characteristics of the activities carried out based on the contract should be presented in this part.

3.     Functional analysis
In the framework of the functional analysis the role of associated companies concerned with the performance of controlled transactions as well as the business risks they bear and the resources they use for the performance are to be presented. Here should also be outlined the resources used and the business risks taken by independent third parties during comparable uncontrolled transactions.

4.     Industry analysis
The industry analysis serves the presentation of the (potential) market of the products or services concerned. In this part, the significant factors affecting the pricing and the market risk should be explored.
In the industry analysis the market share and size, the degree of market liberalization, the competitive situation and the possible replacement goods may be presented. Additionally, the industry analysis may show the ongoing trends which may have impact on the pricing of the transactions.

5.     Economic analysis
The economic analysis includes the examination of the transfer pricing methods. After a brief presentation of all methods, the reason for selection the applied method to determine the market price is to be justified. As mentioned in our previous newsletter, should not one of the denominated methods be applied, the listed ones should be eliminated.
Here are also to be outlined the data used for the comparison, their selection and utilization process, the justification of their application, the comparison tools selected and influencing factors, conditions.

6.     Financial analysis
The last part includes the result of the economic analysis carried out according to the chosen method: the price, price margin, profit calculated on the basis of the comparable products or services and the arm’s length range (interquartile range where applicable) thereof.
The fair market price range obtained during the economic analysis is to be compared with the price applied by the associated company. If the prices between related parties do not meet the independent price range, the correction necessary due to the differences compared to the fair market price are to be documented.
Our summary included the proposed content structure of the stand-alone transfer pricing documentation. The exhaustively list of mandatory elements of the documentation is stipulated in the Decree no. 22/2009 (X.16.) on transfer pricing documentation requirements.
We hope that our summary serves useful for your purposes.

If you are interested in this topic and you would like to learn more about the content of each part of the sand-alone transfer pricing documentation, our experts are at your disposal.

If you need further information related to the transfer pricing rules, please do not
hesitate to contact our experts

 

Contact:

Antretter Erzsébet

Tax Manager

erzsebet.antretter@accace.com

+36 14123547


Read more from the same author
  • Hungarian Transfer Pricing Guide
  • Transfer Pricing Exemption in Hungary

Primary Sidebar

<< Back to newsroom

NEW TO THE MARKET?

Use the free consultancy delivered by our in-country experts to get you prepared.

See what is included and schedule your call now!

We only need your email

Footer

About Accace

Originally established in Central and Eastern Europe in 2006, Accace ranks among the leading outsourcing and consultancy providers in the region. Engaging over 600 experts, we have vast experience with handling small to large scale, multi-country outsourcing projects and providing a comprehensive range of our services to over 2,000 customers.

About Accace Circle

Accace operates internationally as Accace Circle, a co-created business community of like-minded BPO providers and advisors who deliver outstanding services with elevated customer experience. Covering almost 40 jurisdictions with over 2,000 professionals, we support more than 10,000 customers, mostly mid-size and international Fortune 500 companies from various sectors, and process at least 170,000 pay slips globally.

Locations and contacts | Accace Circle

Our services

Accounting and reporting
Payroll and HR administration
Tax advisory
Transaction advisory
Legal advisory
Corporate and secretarial

Our eShop

Market entry support
See full list of services

Our online portals

Accounting portal
Payroll and HR portal
T&A portal
Advisory portal

Get in touch with us

Locations and contacts
Contact us
Sign up for news
Newsroom
Careers


Follow us

Facebook LinkedIn Twitter Instagram Youtube


Accace Circle

© Accace all rights reserved | Code of conduct | General Disclaimer | Disclaimer Newsroom | Cookie policy | Privacy policy | GDPR Statement

Get free access to
valuable insights
expert knowledge

Our legislation updates make it easy for you to keep on top of the latest changes affecting your business. Receive our articles, opinions, tips, industry news, country profiles, regional overviews and studies, latest events and even more, directly into your mailbox.

Check out our Newsroom to see what is included!

We only need your email

We will send you only relevant information we consider may be of your interest and treat your personal data in compliance with our Privacy policy and GDPR statement.

Unable to subscribe?  Try this page.

This site uses cookies. By continuing to browse the site, you are agreeing to our use of cookies. Find out more.