Though they are relatively new in Hungary, advance pricing arrangements (APA) are now quite popular among multinational companies. APAs can be obtained relatively quickly and cost efficiently, in close cooperation with a special team of tax authority professionals. Zoltán Lipták of Ernst & Young says the APA team of the tax authority has a track record of being flexible and cooperative with taxpayers.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
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