Hungary: Changes to transfer pricing legislation expected for 2017

The Hungarian Minister for National Economy submitted a draft bill which would modify the current tax legislation, including certain transfer pricing related amendments.

Prices applied between related parties.

The draft bill sets stricter conditions for the application of tax base deductions in connection with the prices applied between related parties. According to current legislation, the CIT base may be decreased by the difference between the arm’s length price and the price used by the related parties, provided that certain criteria are met. According to the draft bill as of 1 January 2017, a taxpayer wishing to apply such deduction would need to be in the possession of a special statement from its related party – in addition to the criteria already included in the current legislation. In this statement the related party must declare that during the determination of CIT (or equivalent tax) it took into consideration the difference between the applied and the arm’s length price.

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Barbara Behrendt-Krüglstein

Barbara Behrendt-Krüglstein

Senior Manager | Deloitte Tax | Telefon: +43 1 537 00 7112 | E-Mail senden

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