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.
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