Transfer Pricing Advisory Group 

The level at which intra-group prices are set can lead to one of the biggest adjustments to a company's tax returns. How can we assess whether prices paid between connected parties are 'correct' for tax purposes? Transfer pricing is by nature a highly subjective area and this level of subjectivity introduces a potentially high degree of risk.

KPMG's transfer pricing group primarily assists in identifying, prioritizing and managing this transfer pricing risk. In an environment where the majority of cross border trade is between 'related parties', being informed in this risk area is a vital step in being prepared for likely tax authority challenges.


Gabor Beer

Gabor Beer

Partner, Head of Tax and Legal Services

+36 (1) 887-7329

Mihály Gódor

Mihály Gódor



The main work of our group covers the following areas:
  • Transfer pricing reviews – these are designed to assist in identifying related party transactions, potential areas of challenge, materiality of exposure and recommendations on remedial action. Our recommendations are always practically focused, i.e. within the constraints of group policy.
  • Compliance with Hungarian statutory documentation requirements of Decree 18/2003 – although this represents an additional burden, it is also an opportunity to highlight the strengths of a transaction with appropriate presentation and wording. We can assist in either producing guidelines and advice on how to comply or prepare the documentation on your behalf.
  • Drafting transfer pricing policies – for Hungarian groups expanding abroad, we offer structuring advice for related-party prices throughout a value chain. Through our global network of member firms we can establish the parameters for each of the relevant jurisdictions.
  • Dispute resolution – should the tax authorities query any aspect relating to transfer pricing, we offer support in suggesting defense strategies, in preparing documentation or by participating in discussions and tax authority appeals.
  • Arm's length margin support – by utilizing widely accepted databases and search strategies, we are able to provide multiple year data for a variety of profitability indicators in the market. The data we can access allows information to be obtained for a particular country or region. This data can then be used to support a margin under the cost plus, resale minus or another acceptable methodology.
  • Training – for larger groups, we can run training workshops for your accounting department or other personnel covering transfer pricing diagnostics, documentation techniques, co-ordination within the group or any other transfer pricing related subject which corresponds to the particular needs at that time.