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Transfer pricing
DLA Piper Posztl Nemescsói Györfi Tóth & Partners Law Firm

Péter Király is the head of transfer pricing; Levente Torma and Ákos Becher co-head the tax practice, and there are 10 available tax advisors. The firm has experienced increasing demand for transfer pricing compliance and documentation as result of the tax authority increasing its interest in the transfer pricing area and the obligation and modification of it.

Király has successfully challenged a transfer pricing dispute with the tax authority on its calculation of the client’s profit level indicator. He was able to support his client’s intercompany loan, which was consistent with the arm’s length rule by using the client’s parent company’s credit rating adjustment method to establish the risk profile of the borrowing entity. Once this was established, Király was able to prove the interest rate on the loan was consistent with the prices in the benchmarking analysis. 

Torma carried out a transfer pricing analysis for a client to calculate the interest rate on a late payment period, and prepared the interrelated transfer pricing report in line with the formal and complying requirements prescribed by local authority provisions and the expected standards of the Hungarian tax authority.

EY

The EMEIA Tax Center at EY is organised as a supranational entity covering the entire Europe, Middle East, India and Africa (EMEIA) region, with its Intercompany Effectiveness and operational transfer pricing practice serving clients’ needs across all jurisdictions.

Led by Oslo-based partner Sveinung Baumann-Larsen, it brings together multi-disciplinary experience and resources focused on IT, accounting, and tax from the entire region in its work. This work covers some of the leading global companies in their respective fields and includes those involved in retail and consumer products, energy and pharmaceuticals, to name but a few.

Jalsovszky Law Firm

Pál Jalsovszky is the managing partner and leads the tax team at Jalsovszky and Tamás Fehér is an attorney focusing on litigations including transfer pricing. The firm has a wealth of experience with lawyers having comprehensive knowledge and skills gained by working for Big 4 accounting firms. It therefore has the expertise to represent clients in tax disputes in court. 

Fehér assisted a client with determining arm’s length prices and preparing relevant related transfer pricing documents. This was crucial for the client, whose profitability is primarily determined by transactions with associated parties.

Niveus Consulting Group

Janos Giraszin and Lajos Bagdi are the managing partners leading a team of nine professionals. Niveus Consulting Group specialises in transfer pricing advisory and offers transfer pricing services such as, but not limited to, compliance (documentation, Country-by-Country Reporting), risk assessments, tax audit defence, transfer pricing design/optimisation, management of APA procedures. The firm has advised more than 250 local entities in different sectors; however, it does specialise in the construction market. 

Giraszin led an advisory service for a local subsidiary of a multinational construction group to obtain an APA, where the transaction was valued at €10 million a year. Each of the client’s operating companies cross rented assets such as machines, vehicles, tools, etc., between each other, and in order to make the process more efficient all the operating companies needed to transfer their assets to one entity. The client then rents the assets to the associated entities. Because of the size of the restructuring of assets, the client wanted to obtain an APA to mitigate risk for penalty. The firm’s role was to design the transfer pricing, prepare and submit the advance pricing agreement and negotiate with the authority throughout the course of the application.

Orientax Consulting

Karoly Radnai, partner, leads the tax team alongside György Boár and Péter Kiss (experienced transfer pricing practitioners), who were recently promoted to directors. The firm has grown from 18 to 22 fee earners since 2017. It provides all tax services for clients in all major industries such as agriculture, automotive, energy, pharmaceutical and media, but specialises in the latter. The firm has gained multinational clients such as Amazon.com, Netflix, Trenkwalder and more. 

Székely and Kiss advised an international client that makes and sells fiberglass insulation on its transfer pricing policy related to intellectual properties (IP) and to determine the arm’s length price of its intergroup licensing transaction. The team had to review if the underlying IP rights were consistent with the changing local and regional tax law requirements.

Tandax Advisory

Tandax Advisory, a boutique law firm, focuses on M&A, private equity dealings, and other cross-border transactions. It has almost 20 years of experience. Tamas Knebel leads the transfer pricing team and has been focusing on transfer pricing for nearly 15 years, from when the authority instigated a requirement for transfer pricing documentation.

Knebel assisted a technology company based in Hungary on preparing a local transfer pricing file for its intercompany transactions. The client has a large R&D facility and manufactures parts in three separate sites.

WTS Klient

WTS Klient Tax Advisory is a member firm of the WTS Global international tax network. It specialises in VAT compliance and advisory, transfer pricing advisory and documentation services, expatriate services, real estate industry tax services, tax litigations and general tax advisory in all tax areas. Its sector strengths include industrial manufacturing, telecommunication, food, real estate, energy and agriculture. The firm has enlarged its office space and increased staff from 20%.

Reka Kiss, Tamas Gyanyi and Edina Morvai advised a client on a transfer pricing matter regarding the shift of a German-based company’s operation in foreign countries. The trio gave advice and identified the risk of the client changing the functions of its Hungarian/Polish operations and the implications of VAT, local business tax, etc.