Transfer pricing advisory

Transfer pricing and the related documentation obligation is a prior and ever more focused target of tax investigations for a while. The experience shows that the local tax auditors become ever better trained year by year and accordingly, the focus of assessments is moving from simple default penalties to the reveal of tax shortfalls together with the relating disputes. Moreover, this tendency looks to become more intense in the future thanks to the dynamic development of the international (OECD) regulation.


1,000 TP reports
200 Clients
0 Assessment
Niveus Consulting Group is a leading advisory firm of the domestic transfer pricing practice, recently we are handling the transfer pricing challenges of more than 200 of our Clients. Our associates have broad experience in the management of both compliance and advisory projects and in the professional support of tax investigations. Our managing colleagues appeared on several forums in the past years both as authors and as presenters.

In the field of transfer pricing we are pleased to provide our existing and future Clients with the following services.

Compliance Tasks

Within the framework of our service we undertake:

  • The full-scope preparation and yearly update of transfer pricing reports;
  • The preparation of benchmark studies which are one of the most important parts of the TP reports;
  • The review and assessment of existing TP reports by utilizing our broad and up-to-date experience gained during numerous tax authority investigations.

We ensure professional liability for our performance while our fees are always including the support of Clients during tax investigations aiming the TP reports prepared by our associates.

Ad-hoc Advisory

Upon such request we are pleased to provide assistance in the following fields:

  • The examination of TP reporting obligation (examination of associated enterprises / group structures, determination of company size indicators, assessment of intercompany transactions).
  • Professional support of pricing (review, risk assessment, design, implementation).
  • Representation before NAV (management of communication, preparation of comments regarding the tax authority?s records, preparation of appeal documents, negotiation with the associates of the tax authority).

Advance Pricing Arrangements (APA)

We undertake the preparation of APA filings and the full-scale support / management of the relating procedure which is including:

  • The advance (if necessary, anonymous) communication with the competent department of NAV.
  • The preparation and filing of the APA request.
  • The follow up and management of APA procedure until the final resolution.
  • The follow up of the Client by the provision of ad hoc consulting opportunities.

Our managing colleagues have participated in several successful APA proceedings in the past years.

Head of Transfer Pricing Services
+36 30 861 40 09

Should you need any further information regarding our Transfer Pricing Services, please visit the service line?s separate website (http://ncg-tps.hu) or do not hesitate to contact our key professional who will be at your service with pleasure pleasure.

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