SERVICES2018-08-30T03:37:54+00:00

Transfer pricing services

Preparing transfer pricing documentation

  • Preparation of local TP files

  • Updating existing documentations

Benchmark analysis with database screening

  • Determining of the usual market profit range by searching in the database

  • Market analysis based on Amadeus database

Masterfile – Preparation of group level TP documentation

  • Preparation of transfer pricing documentation on a group level

  • Localisation of documentation prepared by the foreign parent company

Preparation of transfer pricing policy

  • Setting a transfer pricing policy for the members of the group

  • Assistance in preparing plans for the management of TP risks assumed

Transfer pricing education

  • Guidance and training for the preparation of the documentation

  • Giving certified lectures on transfer pricing for auditors, accountants, tax advisors and tax specialists

Preparation of APA request

  • Preparation of the request of the determination of the arm’s length price by the Tax Authority

  • Representation in front of the Tax Authority in connection with the APA request

Legal representation in front of the Tax Authority

  • Provision of professional support during the tax revision

  • Representation in front of the appellate forums of the Tax Authority and/or the Court

TP Health check

  • Professional audit of existing transfer pricing documentations

  • Supervision of the fulfilment of the formal and content requirements

  • Examination of the practical application

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Unique TP documentation – in accordance with the legal regulations and expectations of the authorities

Kondor-TP places emphasis on the consistency of the method used for the establishment of the arm’s length price and the expectations of the Tax Authority and the Ministry of Finance.

Preparing a transfer pricing documentation requires complex and unique effort, since contrary to other internal regulations (for example accounting policy) in the case of transfer prices, there is no such sample documentation that can be used for all the companies with little corrections.

The Tax Authority may levy significant penalties if the transfer prices applied between the related companies do not correspond to the prices applied between independent parties in the same circumstances. That is why it is important to have experienced advisors assist You, and that the precise and exhaustive work we provide to serve as a reassuring and safe background to the business operations of your company.

Why is it advisable to work with an experienced and competent transfer pricing expert?

  • The company’s TP risks assumed are going to be minimised;

  • Kondor-TP continuously monitors the tendencies of the tax audits, the resolutions issued by the Tax Authority, the changing legislation – so this burden does not lie with the company anymore;

  • Kondor-TP provides information in the management letter on the risks assumed in connection with the transfer prices applied in the transactions between the related parties, and the possible solutions as well.

The steps of the preparation transfer pricing documents:

  • Request of the documents and information that are necessary for the preparation of the documentation (sending out a questionnaire);

  • Preparing the draft transfer pricing documentation;

  • Receiving comments and questions of the Client;

  • Preparing the final transfer pricing documentation.

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Commitment and quality guarantee

Since the introduction of the transfer pricing legislation in 2003, the Tax Authority pays special attention in its audits to transfer prices and related parties. If the parties did not apply appropriate prices in the transactions among each other, the Authority may impose serious penalty on them.

In order to avoid the abovementioned scenario, it is the task of KONDOR-TP to provide assistance and advice tailored to Your needs as possible. We are aware that in this field, every mistake may have severe consequences, so we work with colleagues who gained their transfer pricing experience at the Tax Authority and/or at the largest international tax advisor companies. Besides the knowledge of international best practices, they also know the specificities of the revision procedures of the local Tax Authority.  Full commitment and experience mean quality guarantee..

In every case we adapt our services to the requirements of the Client. As part of our advisory services our advisors examine the transactions between the related parties or the transfer pricing documentations that are already prepared by the Group, and they also provide a summary of their expert opinion on them.

If required, we help our clients to prepare the whole transfer pricing documentation or specific parts of it (for example choosing the appropriate method or preparing benchmark analysis). We also can assist in drawing up APA requests or requests for resolution of the Authority in specific issues. Our objective is to defend the pricing practices of our clients during a tax revision, so to avoid transfer pricing penalties and even the administrative burden of a complex tax audit.

Transfer pricing in general

Usual market prices are applied in transactions between independent parties in accordance with the market conditions. However it is possible that the contracting parties are not independent, but are related parties. Companies are deemed to be related parties if the owners are the same, one company is the majority owner of the other one, or the domestic company has a foreign parent company, etc. – but other factors can result in related party relationship according to the definition of the Act on Corporate Income Tax.

In the case of related parties, the prices applied in the transactions between the parties are called transfer prices. Transfer prices can affect the profits of the companies involved and the amount of tax due. In Hungary, the obligation to prepare transfer pricing documentations was introduced in 2003, and since then prices applied between related parties are a matter of priority in the audit policy of the Tax Authority. Companies having related party transactions shall have a specific transfer pricing documentation on the prices applied if the transaction value is above a certain threshold.

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