In the audit practice of the Hungarian Tax and Customs Administration (HTA), the audit of transfer pricing is gaining importance. Moreover, the relevant regulations are becoming more complex with each passing year. As the deadlines for transfer pricing documentation approach, it is worth reviewing what hidden pitfalls should be avoided when preparing documentation and providing data.
The title may sound like a bogus question – but it is far from it. What many people do not know is that cash payments are prohibited or restricted between businesses in many cases. And even fewer people know that cash payments over a certain threshold are subject to the full rigour of money laundering regulations.
The most common form of corporate financing among owners is still the member’s loan. But many forget that while granting a member’s loan is relatively easy, it hides several ticking time bombs – as a recent Supreme Court decision confirmed. Fortunately, there’s already a risk-free capital contribution option.
The recently adopted tax law changes significantly expand the definition of related parties. As of 2015 not only those companies will qualify as related parties which are connected in their ownership chain, but also those with an overlap in their management. As a result, the number of transactions where parties have to apply arm’s length pricing will increase. The new definition may, however, cause uncertainties as well.
The law is constantly in flux. While many people may find this intimidating, for us it’s precisely what makes it so exciting. We’d like to share this attitude with businesspeople and managers, and with those who just have an interest in business law, in the form of a regularly updated blog that discusses the latest tax law and commercial law issues in an accessible style. Feel free to send your questions and suggestions for topics you’d like us to cover to blog@jalsovszky.com.
