Transfer pricing briefing for November 2014

The OECD has issued two important papers since my last transfer pricing briefing. These relate to low value-adding intra-group services and the avoidance of permanent establishments. As these have been covered in separate articles in last week’s edition of Tax Journal I am going back to a round-up of country level developments this month.

Hungary

Tax law changes to be implemented for 2015 presented to the Hungarian parliament in October contained a number of transfer pricing points. Hungary’s transfer pricing legislation (Corporate Tax and Dividend Tax Act LXXXI of 1996) adopts the arm’s length principle. The Hungarian regulations have been developed ‘with regard to’ the OECD’s model tax convention and transfer pricing...