HUNGARY: IMPLEMENTING TRANSFER PRICING-RELATED BEPS ACTIONS
Action 13 of the final package of reports issued by the Organisation for Economic Cooperation and Development (OECD) under the base erosion and profit shifting (BEPS) project focuses on a company group’s global value chain and transfer pricing policy, and introduces a standardized three-tiered approach to transfer pricing documentation—core documentation (Master file), detailed country-specific transfer pricing documentation (Local file), and country-by-country (CbC) reportin
TIMING FOR IMPLEMENTATION INTO HUNGARIAN LAW
The expected timeframe for the implementation of BEPS Action 13 (as well as the entire BEPS package) into Hungarian law is unclear.
In Hungary, the transfer pricing documentation concept based on Master file and Local file—similarly to the system currently recommended by OECD—is already established.
Nevertheless, concerning the CbC reporting, and independent of the timing of domestic implementation, Hungarian taxpayers may be affected by the related data gathering and other obligations required by their parent entities. Therefore, these entities may want to consider whether their current internal accounting and reporting systems are appropriate for collecting such information.
Read an October 2015 report prepared by the KPMG member firm in Hungary: Final version of the BEPS transfer pricing documentation concept has been published