This is the first time since the introduction of the Hungarian transfer pricing regulation that specific guidance on the use of transfer pricing specific databases containing data at company level has been published. The communication issued by the Hungarian Tax and Customs Administration (NAV) also clarifies the most important steps of the database research and the importance of manual filtering.
Pursuant to Ministerial Decree no. 32/2017 NGM imposing the obligation to maintain transfer pricing documentation, the benchmarking analysis is a mandatory element of the local file. Overall, even before the publication of the communication, a general practice has been established among taxpayers for the preparation of benchmarking analyses, such as the use of databases containing company-level data or the steps followed in the database search, and manual screening has also become a common practice.
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