Hungarian tax liabilities of companies and individuals with U.S. business interests may change significantly from 2024
During recent months, the United States terminating the tax convention for the avoidance of double taxation with Hungary has been a hot topic. In July 2022, Hungary received a notification of termination from the United States. As of 1 January, 2024, this treaty will no longer be applicable.
government proposes new tax package with restrictive measures on transfer pricing
On the 23 June 2022, Law Amendment Proposal Number T/360 on Hungary’s 2023 State Budget was presented to Parliament by Finance Minister Mihály Varga, which can also be deemed as this year’s relevant tax package.
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Deloitte transfer pricing professionals help multinational companies to price their intercompany transactions, such as sales of goods, the provision of services, and transfers of intangible property, and to document, support, and defend the pricing for such transactions.
Global Tax Reset - Transfer Pricing Documentation Summary
Deloitte's Transfer Pricing practice has prepared the Global Tax Reset - Transfer Pricing Documentation Summary, which compiles essential country-by-country reporting and documentation information (including master file/local file information, if applicable) for 136 jurisdictions around the world.
Significant changes in the transfer pricing documentation rules
Errors in documentation may lead to large fines
Due to the regulatory changes, preparation of the transfer pricing documentation may place a bigger administrative burden on companies, so it is worth starting it as soon as possible and leave more time for this task than before.
New transfer pricing regulation – focus on profitability calculation
Transfer pricing remains a priority audit area for the tax authority. For financial years beginning on or after 1 January 2018, taxpayers are required to prepare their transfer pricing reports according to the provisions of NGM decree no. 32/2017. (X.18.) (hereinafter: “NGM decree”).
Corporate taxpayer groups: can transfer pricing requirements be overlooked?
As a general rule, although itemised transfer price adjustment and documentation regulations of the corporate tax act are not applicable for transactions between companies involved in group corporate taxation, liabilities regarding transfer pricing may still arise for them.