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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Despite the relief, Brazil’s government has also presented a bill which seeks to re-impose a tax burden on companies’ payroll, one local tax specialist told ITR
While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort