Rudolf Szabó

From 2026, several elements of established professional practice for transfer pricing database searches become statutory requirements. Alongside selecting an appropriate set of comparables, taxpayers must provide detailed evidence of the search process and the rationale for the screening criteria applied. Our article reviews the requirements for conducting, updating and documenting searches so that the process can be traced and reproduced.

Accounting for intra-group services requires evidence of actual delivery and local business benefits alongside the contract and invoice. Our article explains how to carry out the benefit test, which activities require particular attention and what documents can substantiate the services received. We also examine the implications for corporate income tax and input VAT deduction.

The allocation of income from intangibles depends on both legal ownership and actual value creation. The transfer pricing decree applicable from the 2026 tax year requires affected groups to undertake a more detailed assessment. Our article examines the key aspects of DEMPE analysis, the importance of decision-making and control over risks, and the documentation requirements.