Countries: Hungary

Hungary vs “Gas-Trader KtF”, November 2022, Supreme Administrative Court, Case no Kfv.I.35.343/2022/8

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“Gas-Trader KtF” – a subsidiary in the E.ON group – had entered into loan agreements with other group companies and the related parties had determined the interest rate by application of the CUP method using the Thomson Reuters LoanConnector database. Comparable transactions was extracted from the database by searching for credit rating, type of debtor […]

Hungary vs “Meat Processing KtF” August 2022, case no K.700777/2022/18 (6-KJ-2022-786)

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Meat Processing KtF recorded “advance receivables” from related companies in FY 2016. The tax authority found that the invoices received by Meat Processing KtF did not contain any reference to the advance payment, the creation and repayment of the receivables were not linked to the ordering or receipt of specific goods, the payment and repayment […]

Hungary vs VSSB V. Service Center Budapest Zrt., December 2021, Court of Appeals, Case No. Kfv.V.35.184/2021/16

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The VSSB Group provided liquidity to the group members by means of a cash-pool. Under the cash pool agreement, short-term and longer-term multi-currency financing transactions were carried out, including the applicant as a member of the group; the intermediary was the group member VSSB V. Service Center Budapest Zrt. (‘VSSB’). At the end of each […]

Hungary vs “Stream-Heat”, May 2021, Court of Appeals – Curia, Case No. Kfv.I. 35.174/2021/7

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“Stream-Heat” is active in the production of steam, heat and electricity, which it sells to its parent company on a cost recovery basis. By agreement between the parent company and Stream-Heat, the consideration for the supply of energy was fixed in the form of a RÁD (availability fee) and an energy fee. Stream-Heat’s results for […]

Hungary vs “Auto Parts Ktf”, May 2020, Supreme Court (Kúria), Case No. Kfv.I. 35,618 / 2019/11

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Auto Parts Ktf’s principal activity is the manufacture and sale of passenger cars and spare parts. Between 1 January 2013 and 31 December 2014, it sold its products to its affiliated undertakings and to unrelated parties. Auto Parts Ktf had prepared transfer pricing documentation, in which it determined the arm’s length price using the transaction […]

Hungary vs “Lender” Kft, February 2020, Budapest Administrative Court, Case No. 16.K.33.691/2019/18

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In 2008 Lender Kft. entered into a loan agreement with its foreign domiciled affiliated company Kft. 1. According to the terms of the contract, the loan amounted to 53,174,516, the maturity date of the loan was 31 January 2013 and the interest was paid semi-annually at the semi-annual CDI rate fixed in the contract plus […]

Hungary vs “Auto Parts Ktf”, May 2019, Administrative Court, Case No. 1.K.27.084 / 2019

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Auto Parts Ktf’s principal activity is the manufacture and sale of passenger cars and spare parts. Between 1 January 2013 and 31 December 2014, it sold its products to its affiliated undertakings and to unrelated parties. Auto Parts Ktf had prepared transfer pricing documentation, in which it determined the arm’s length price using the transaction […]

Hungary vs “Seeds Kft”, September 2018, Supreme Administrative Court, Curia No. Kfv. VI. 35.585/2017

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The Hungarian tax office had carried out an an audit of “Seeds Kft” – a group company engaged in the trade in cereals and oilseeds – in relation to accounting for commodity futures. In the assessment decision, the tax office emphasized that the economic substance of the given transaction and the purpose to be achieved […]

Hungary vs Trademark Ltd, May 2015, Appeals Court Curia No. Kfv. I. 35.774/2014

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The Hungarian company “Trademark Ltd” was involved in distribution of trademark rights. Trademark Ltd obtained the trademark rights from affiliated companies in Luxembourg and Barbados and then also passed trademark rights on to other affiliated company. For the purpose of determining the remuneration, only one company in the group had a transfer price record. According […]