Tax Alert

We would like to inform you that, in connection with the new transfer pricing reporting obligation introduced for the first time in corporate tax returns submitted after December 31, 2022, the content of the ATP data sheets for corporate tax returns were changed at the beginning of 2024 with the publication of the new tax return form.

With the approaching deadline for corporate income tax return filing – along with the preparation of transfer pricing documentation – new corporate tax return form (2329) is now available. This contains the new ATP data sheets to be filled out in connection with the disclosure of transfer pricing related data. The content of the data sheet has changed in several regards.

The most important changes to the transfer pricing reporting data sheets are:

• If the consolidated approach is followed, justification must be provided for choosing this approach.
• The tested party has to be indicated.
• Clarification in terms of transactional values, values may only be defined in HUF. Negative values may also be entered.

How Can We Help?

Although the relevant legislation has not changed, it can be concluded from the above and our experience during tax audits that the actual content of transfer pricing reporting is still a developing area to which the Tax Authority pays special attention when handling tax returns.

Based on our latest tax audit experiences, transfer pricing documentation has become even more important with the introduction of the new obligation. During tax audits, considerable attention is paid to both the transfer pricing reporting data sheets and the reported data. It is therefore vital that the data sheet should be filled in with the most appropriate data, thereby helping in the process of tax authority investigations.

Our team of experts will be happy to assist you in fulfilling the obligation of transfer pricing reporting as well as the transfer pricing documentation obligation.