BPO AUDIT TAX

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transfer pricing

Changes in transfer prices in 2018

| Wrote: László Killik, Renáta Béres
The two-stage structure becomes mandatory, which in realty has three levels: Master File; Local File, CbCR report
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international, local transfer pricing•  Master File
Includes, for example, the consolidated financial statements of a group of companies, details of the presentation of an intra-group financing, the presentation of products and services with a significant turnover and their intra-group circulation.

•  Local File
The number of simplifications and exempts is reduced. More stringent analytical requirements have been specified. Annually updated data!

• CbCR report
For multinational enterprise groups with a consolidated annual sales turnover of over EUR 750 million. From the financial year beginning on or after 1 January 2016, there is a obligation to disclose or report information to the state tax authority.

Form 16CBC published by the tax authority (NAV)in September 2017 is for the purpose of disclosing information on the distribution of profits, taxes and business activities of the group, according to the tax jurisdictions.


What details are required for 17T201T form?

For the ultimate parent of a Hungarian tax resident group member or for an organization designated as the ultimate parent

• Hungarian tax resident group member
• name, registered seat, tax identification number
• status of ultimate parent, organization designated as the ultimate parent or group member required to disclose information
• the last day of the reporting financial year

For a Hungarian group member, which does not qualify as an ultimate parent or organization designated as the ultimate member

• Hungarian tax resident group member
• name, registered seat, tax identification number
• lack of the status of ultimate parent, organization designated as the ultimate parent or group member required to disclose information
• the name and tax residence of the organization required to submit the report  (including the country code).

The notification deadline for the reporting financial year is the last day of the financial year; in case of a financial year based on a calendar year the deadline is December 31.




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