Page 1

Hungary Extends Exemptions for Transfer Pricing Documentation (Sunnyvale, CA) - Hungary has implemented changes to the transfer pricing (TP) documentation requirements extending scope of exemptions. However, new exemptions can only be availed by taxpayers for the tax year 2012 and whose documentation are not due before January 1, 2013, says Nair & Co.’s International Tax Consulting Team. New TP Documents Obligations Provide for the Following Changes to the Exemptions: 

For advance pricing agreements (APAs), the exemption in regards to TP documentation is extended to the tax year wherein the application for a resolution is submitted till the last day of the tax year for which the resolution holds good. The following points must be noted:  The earlier rules referred only to the resolution’s validity.  The exemption is applicable only when the vital facts and situations mentioned in the APA regulations are constant all through this period. If the total historic value of transactions is below HUF 50 million (exclusive of VAT), the exemption from documentation obligations becomes available. In addition, all transactions made in the same tax year are taken into account collectively. Previously, the threshold limit was computed from the date of signing of contract till the end of the tax year. The following points must also be noted:  While working out the threshold, in case the amount of the transaction is in an overseas currency, the exchange rate for the conversion to HUF will remain same as used in the books by the taxpayers.  In case the books are not maintained in HUF, the exchange rate of the Hungarian National Bank on the last day of the tax year would be applicable. In case there is no exemption, the TP documentation requirement must be fulfilled on transactional basis.

For more information about doing business overseas or to know more about our International Expansion Services team please contact us. Subscribe to regular global tax compliance alerts from Nair & Co. International Business Guide (IBG) is our online platform for companies wishing to optimize their multinational operations and would like to have specific business information for doing business in a particular country - Click Here. Get the latest news releases and updates on international tax, HR, Finance, compliance and other legal news at Nair & Co. Industry Alerts.

About Nair & Co. Nair & Co. provides you with your one touch outsourced finance, HR, legal and global tax compliance department for your international operations. If you are expanding abroad for the first time or increasing your global footprint, our turnkey solutions help you do so with minimal risk, stress and cost. We support 1000+ client operations in over 56 countries and have core offices in U.K., India, China, U.S., Japan and Singapore. Nair & Co. was named among the top 100 outsourcing services providers in the world by the International Association of Outsourcing Professionals (IAOP). Learn more at Read more on: Tips for expanding your business overseas

Hungary Extends Exemptions for Transfer Pricing Documentation  

Hungary has implemented changes to the transfer pricing (TP) documentation requirements extending scope of exemptions, says Nair & Co.’s...