Hungary: Audit plan for 2024 focuses on transfer pricing

New transfer pricing reporting requirement can be used for risk assessment and tax audit selection purposes in 2024

Focus on transfer pricing

The National Tax and Customs Administration published its audit plan for calendar year 2024, in which it confirmed that transfer pricing will be a priority in multiple areas.

The new transfer pricing reporting requirement, which was introduced in the previous tax year, along with the first data submissions, can be used for risk assessment and tax audit selection purposes in 2024.

The audit plan specifically mentions transfer pricing relating to the following areas:

  • Audits of related-party transactions in automotive industry
  • Transfer pricing specific audits of pharmaceutical entities
  • Verification of compliance with the conditions of advance pricing agreements (APAs) and transfer pricing data reporting
  • Verification of country-by-country (CbC) reports and transactions identified as risky on the basis of cross-border arrangements
  • Transfer pricing audits of taxpayers with loss-making or very low profitability who are engaged in intra-group manufacturing activities
  • Audits of related-party transactions involving intangible assets
  • Audits of loan or other financial transactions between related companies

Read an April 2024 report prepared by the KPMG member firm in Hungary



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