At least HUF 2 million and a maximum of HUF 7 million in fees if the traditional method based on th

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There is a fair reward for the NAV-smokers star distributors receive when tax revenues are taken
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While similar requests from 2007 to 2010 occurred 24 times the NAV to, until the end of 2013 had more than 85 applications were submitted. In 2010, a total of 13 cases were appealed to the National Tax and Customs Administration of large companies last year, it had sought to establish a preliminary price transactions star distributors between affiliated companies 20 times. This year, 11 in the first half of this type has been lodged.
DLA Piper tax advisory firm said is related to the trend by 2010 compared to previous years revealed a record high, amounting to over 33 billion forints net tax difference in transfer pricing audits, and the number of requests for further increase is expected in the future.
"The big companies caution is explained by the increasing rigor of tax inspectors, which is revealed in the course of transfer pricing tax audits margins, star distributors as well as increasing star distributors the amount of the fines is reflected in both" - says Peter King, the head of DLA Piper transfer pricing division.
"2010 was a record high compared to previous years, the final net tax established by the tax inspectors. This amounted to HUF 33 billion, 865 million and, simultaneously, the tax rate of the fines was also a record at HUF 12 billion 673 million imposed in the NAV. It was a pretty strong message to companies that if they want to avoid the tax differentials finding and related penalties, you should consult the authorities in advance of future transactions linked to transfer pricing management "- added the expert.
The procedure may apply to the taxpayer and the tax authority subsequently determines star distributors the decision to be enforced transaction star distributors between associated enterprises normal market price and the price range they determine star distributors the method used.
The period covered by the Decision taxpayers do not have to prepare transfer pricing documentation star distributors for that transaction. The NAV of the decision issued by at least three and up to five years, star distributors which may be extended once for a period of three years.
If you just buy the proceedings, the Hungarian tax authority involved star distributors in the award of 500 thousand forints and up to HUF 5 million in the event that if the fair market price of the comparable uncontrolled price, resale price and the cost plus method established.
At least HUF 2 million and a maximum of HUF 7 million in fees if the traditional method based on the three different methods to determine star distributors pricing. If the foreign tax authority should also be involved, it ranges from HUF 3 million to 10 million of the total cost.
"Looking at the data clearly show that the tax authorities investigate transactions between affiliated companies in line with international practice special attention, so the future is expected to further increase in the number of applications for the arm's length price for the advance fixing, star distributors even if the magnitude of growth is not expected" - he said The King Peter.
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