Structural changes at the Tax Authority

Bits of transfer pricing

Following a reorganisation in the transfer pricing functions at the Hungarian Tax Authority (HTA) early this year, separated departments were created to fulfil the principle of division of units dealing with APA requests and transfer pricing related tax audits.

APA department functions as part of the Headquarters of HTA from January 2017. This body is responsible for dealing with all types (uni-, bi-, multilateral) of APA procedures and also has the task to solve MAP and arbitration processes.

In the new structure, the Transfer Pricing Audit Unit operates as a department of the Large Taxpayers Directorate. It is competent in audits carried out at the biggest companies seated in Budapest and Pest county and also provides technical support to tp auditors acting countrywide.

The change ensures having a Chinese wall between the two tp related functions and, with dedicated task force, projects a stronger focus on transfer pricing investigations with more consistent quality.