There have been significant changes in transfer pricing in the past year. Previously, it was still mandatory to keep records above certain thresholds, but from 2022, companies subject to the obligation will be required to include the most important information from the documentation prepared in the corporate tax return (ATP-01 and ATP-KV). If a company fails to do so and is found to be non-compliant during an official audit, it could face fines of up to several million euros per transaction. It is also important to know who is exempt and which transactions are partially exempt from transfer pricing documentation," says Csaba Szabó, Professional Director of ICT Europa Finance Zrt.
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