Tag: Transfer pricing information

Poland – Ordinance No. 1934 on Transfer Pricing-Documentation

Polish Ordinance No. 1934 of August 29 2022 on transfer pricing documentation. The new ordinance sets out the detailed scope of data and information and the content of the statement contained in the corporate income tax transfer pricing documentation together with explanations on how it should be prepared. Click here for unofficial English translation Click here for other translation ...

Hungary – Legislation on use of Interquartile Range and Median

As part of tax legislation recently enacted in Hungary, rules governing the application of statistical tools – arm’s length range and adjustments within the range – will now be governed by law. When determining arm’s length prices based on benchmarks of comparables it will now be mandatory to use the interquartile range. If the price falls outside the arm’s length range, adjustment must be made to the median value – unless the taxpayer can prove that another value within the range is more appropriate. Where the price is within the arm’s length range, taxpayers will no longer be allowed to make year-end adjustments. The above amendments will have effect for FY 2022 and forward. Furthermore, certain information related to controlled transactions will now have to be provided in the corporate tax return. Details in this regard will be contained in a later Ministerial Decree. Click here for unofficial English translation Click here for other translation ...