Interpretative Statement Issued by the Tax Authorities on the Application of the Arm’s Length Principle to a Loan Guarantee Agreement

Journal
Gódor, M.
Hungary
International Transfer Pricing Journal 2013 (Volume 20), No. 5
FormatPDF
USD
50

The author considers recent guidance from the Hungarian tax authorities on the application of transfer pricing adjustments to intercompany transactions subsequent to a change in status as related parties.