Transfer pricing Advisory
We don't drift. We set the course.
Transfer pricing is no longer merely an annual documentation obligation. Pricing between associated enterprises directly affects corporate income tax, group-level profit allocation, NAV risks and the predictability of international operations.
Crowe FST’s transfer pricing advisory service provides structured support to medium-sized and large companies, as well as Hungarian and international corporate groups: from preparing documentation, preparing and reviewing the master file and local file, through benchmarking analyses, transfer pricing policies and intra-group pricing matters, to professional support during tax authority audits.
Request a consultation with our experts, or send us your request for a proposal
Where we add value
Documentation that is not prepared merely as a formality
We do not treat transfer pricing documentation as a formal obligation. We do not prepare template-based documentation, but rather professional substantiation where the business facts, financial data and transfer pricing methodology all point in the same direction.
Documentation that is not prepared merely as a formality
Benchmarking and comparative analysis
We substantiate the compliance of associated-party transactions with the arm’s length principle through benchmarking based on major international databases, appropriate transaction characterization, functional analysis and economic rationale.
Benchmarking and comparative analysis
Group-level thinking with Hungarian compliance
We help align the group-level transfer pricing policy, master file and local file with Hungarian transfer pricing requirements and NAV audit expectations.
Group-level thinking with Hungarian compliance
Managing tax authority risks
Transfer pricing is a key focus area for NAV audits. We provide support in risk identification, addressing documentation deficiencies, NAV audits, disputed matters and developing professional positions.
Managing tax authority risks
When do clients usually contact us?
- when fulfilling the annual transfer pricing documentation obligation or reviewing existing documentation,
- before entering into a new associated-party transaction, service model, financing arrangement, royalty arrangement or business restructuring,
- if the group master file or central transfer pricing policy requires supplementation from a Hungarian legal or NAV audit perspective,
- when preparing a benchmarking study, database search, competitor analysis or determining an arm’s length price range,
- when preparing for a NAV audit, or in the event of a transfer pricing-related tax authority question or dispute,
- if the pricing between associated enterprises no longer properly reflects the actual functions, risks or use of assets,
- when assessing the transfer pricing implications of an acquisition, group restructuring, new regional model or cross-border structure.
How can we help?
Transfer pricing documentation and review
We prepare and review Hungarian transfer pricing documentation files, including the master file and local file, and align them with group-level documentation. We help identify associated-party transactions, prepare functional and risk analyses, and professionally substantiate the selected transfer pricing method.
Benchmarking studies and economic analyses
We prepare database searches, comparative analyses and competitor analyses for loan transactions, intangible assets, services and other associated-party transactions. We determine the relevant market price or profitability range and substantiate the arm’s length nature of the applied pricing or profitability.
Transfer pricing policy and intra-group pricing
Development or review of group-level transfer pricing policies, and transfer pricing treatment of service fees, management fees, manufacturing and distribution models, financial transactions, intangible assets and royalties.
We prepare and review Hungarian transfer pricing documentation files, including the master file and local file, and align them with group-level documentation. We help identify associated-party transactions, prepare functional and risk analyses, and professionally substantiate the selected transfer pricing method.
We prepare database searches, comparative analyses and competitor analyses for loan transactions, intangible assets, services and other associated-party transactions. We determine the relevant market price or profitability range and substantiate the arm’s length nature of the applied pricing or profitability.
Development or review of group-level transfer pricing policies, and transfer pricing treatment of service fees, management fees, manufacturing and distribution models, financial transactions, intangible assets and royalties.
Data reporting, CbCR and compliance support
Support for transfer pricing-related data reporting obligations, CbC reporting matters, documentation deadlines and internal compliance processes.
Year-end adjustments and control points
Year-end transfer pricing adjustments, margin monitoring, development of control points, and assessment of whether intra-year pricing and year-end results are aligned with the transfer pricing policy.
NAV audits and support in transfer pricing disputes
Preparation for audits, identification of documentation deficiencies, preparation of professional responses, support in tax authority communication, and professional handling of transfer pricing disputes and high-risk transactions.
Support for transfer pricing-related data reporting obligations, CbC reporting matters, documentation deadlines and internal compliance processes.
Year-end transfer pricing adjustments, margin monitoring, development of control points, and assessment of whether intra-year pricing and year-end results are aligned with the transfer pricing policy.
Preparation for audits, identification of documentation deficiencies, preparation of professional responses, support in tax authority communication, and professional handling of transfer pricing disputes and high-risk transactions.
APA and advance pricing agreement options
Where necessary, we provide support in assessing whether it is justified to prepare an advance pricing agreement request or another solution agreed with the tax authority.
Where necessary, we provide support in assessing whether it is justified to prepare an advance pricing agreement request or another solution agreed with the tax authority.
Why Crowe?
International network, local compliance
The Crowe Global network supports the coordination of transfer pricing matters involving multiple countries, while the documentation and related advisory services are tailored to Hungarian transfer pricing rules, documentation requirements and NAV audit practice.
International network, local compliance
We start from the business model, not from a template
We do not prepare template-based documentation. We interpret associated-party transactions based on actual functions, risks, assets, decision-making powers and economic reality, so that the transfer pricing documentation reflects the true operation of the transaction.
We start from the business model, not from a template
Combining tax and financial perspectives
In addition to regulatory requirements, we build transfer pricing documentation on the company’s financial data, business operations and group-level settlement logic. This results in professional material that not only formally meets expectations, but also presents the economic substance of associated-party transactions in a clear and defensible manner.
Combining tax and financial perspectives
Audit-ready documentation and decision support
Our goal is for the client to receive not only completed documentation, but also professional material and a position that can be used during NAV audits, internal decision-making and group-level discussions.
Audit-ready documentation and decision support
The following information helps us provide a quick and accurate proposal:
the list of associated enterprises, a brief description of the main associated-party transactions, the group master file or transfer pricing policy, previous documentation, and an indication of whether transfer pricing documentation, a benchmarking study, a review or NAV audit support is required.
Request a consultation with our experts, or send us your request for a proposal
Frequently asked questions
Who is required to prepare transfer pricing documentation?
In general, companies may have a transfer pricing documentation obligation if they carry out transactions with associated enterprises and are required to prepare transfer pricing documentation under the relevant Hungarian rules. The exact obligation must always be assessed based on the company’s size, transactions and applicable exemption rules.
Is the master file prepared by the group sufficient?
Not necessarily. The group master file can be an important basis, but from a Hungarian perspective it must be reviewed to determine whether it complies with domestic transfer pricing documentation requirements. If it does not contain all relevant information, the document may need to be supplemented or restructured.
When is it worth preparing a benchmarking study?
A benchmarking analysis is needed when the price or profitability of an associated-party transaction must be substantiated with comparable data from transactions between independent parties. Typical cases include the introduction of a new pricing model, the review of existing documentation, the preparation of year-end price adjustments or the management of NAV risks.
In general, companies may have a transfer pricing documentation obligation if they carry out transactions with associated enterprises and are required to prepare transfer pricing documentation under the relevant Hungarian rules. The exact obligation must always be assessed based on the company’s size, transactions and applicable exemption rules.
Not necessarily. The group master file can be an important basis, but from a Hungarian perspective it must be reviewed to determine whether it complies with domestic transfer pricing documentation requirements. If it does not contain all relevant information, the document may need to be supplemented or restructured.
A benchmarking analysis is needed when the price or profitability of an associated-party transaction must be substantiated with comparable data from transactions between independent parties. Typical cases include the introduction of a new pricing model, the review of existing documentation, the preparation of year-end price adjustments or the management of NAV risks.
Can you also provide support during NAV audits?
Yes. We provide support in reviewing documentation, identifying risks, preparing professional responses and handling transfer pricing matters during NAV audits.
When is it worth developing a transfer pricing policy?
When intra-group transactions are regular, involve several countries or several companies, or when a new business model, financing structure, service fee or pricing mechanism is introduced. A well-developed policy helps ensure that pricing is consistent, documentable and defensible during an audit.
Yes. We provide support in reviewing documentation, identifying risks, preparing professional responses and handling transfer pricing matters during NAV audits.
When intra-group transactions are regular, involve several countries or several companies, or when a new business model, financing structure, service fee or pricing mechanism is introduced. A well-developed policy helps ensure that pricing is consistent, documentable and defensible during an audit.
Balázs Földes
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