In recent years the Hungarian Tax Authority (HTA) has been concentrating more and more on transfer pricing issues and has publicly formulated views in relation to comparable searches. Zoltán Lipták and Hedvig Sólyomvári of Ernst & Young provide an overview of the most important aspects of these views and raise some questions in relation to their practical implications in light of the latest advance pricing agreement (APA) and tax controversy experience gathered by tax advisers.
Unlock this content.
The content you are trying to view is exclusive to our subscribers.
HMRC expects advisers to meet ever-higher compliance criteria. After 24 consecutive qualified audit opinions, many will ask whether HMRC should hold itself to the same standards
Hany Elnaggar examines how the region's legacy economic substance regimes and the OECD's pillar two framework are converging on the same underlying test
The deals for TP Accurate and Intra Pricing Solutions will enhance Alphatax’s ability to support clients with the full TP lifecycle, the tax tech provider claimed
Lindsay Clayton’s arrival at Baker McKenzie continues the firm’s storied pursuit of ex-US government lawyers, a strategy reinforced by robust World Tax rankings
As pillar two reshapes global tax competition, the UK faces a crucial challenge: how to remain attractive to multinationals without sacrificing tax revenues