Who is obliged to produce a Master File?

Every business organization that is engaged in transactions with related parties, which are not exempt from the requirement of making documents, in addition to the Local File they are also obliged to create a Master File.

The aim of the Master File

The Master File aims at giving the tax authority carrying out the verification of the transfer pricing documentation a comprehensive picture of the operation of the group, getting to know the main business lines, primary products and services; getting an insight into the main value creating line within the group of companies, and getting to know the functions of some companies.

In addition to the above control aims by providing the obligation to create the main document, the business will be exempt from the punishment by fines for the absence of the Master File, the amount of which can be HUF 2 million per year.

Our services in relation to the Master File

• Creation of the Master File in Hungarian, in German or in English.
• Review of the centrally created Master File in the sense whether it meets the demands of the Hungarian legislation. If it does not, what needs to be added to the main document created centrally so that it could be part of the Hungarian transfer pricing documentation?
• Representation before the tax authority in transfer price auditing procedures.
• Advisory services about transfer pricing.