Michaela Merz


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TP – The OECD released a final paper on Financial Transactions Transfer Pricing


The OECD published a new chapter of the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Authorities (“the OECD Guidelines”). The new chapter provides guidance on the transfer pricing for loans, guarantees, cash pools, hedging and captive insurance transactions.

The new chapter is the first OECD guidance on transfer pricing for financial transactions issued in final form and will be the main reference point for pricing and auditing related party financial transactions in most countries going forwards.

Loan, guarantee and cash pool policies that Swiss groups apply across their international operations should be reviewed and updated to ensure compliance with the new guidance.

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License for importation self-assessment in Hungary


Hungary is the country with the highest VAT rate (27% standard rate) within EU. In case of a business model where the importation of the goods cause negative cash flow effect due to high recovery position of import VAT one should be proactively thinking to get a license for importation self-assessment. It’s a license that can be obtained from the National Tax and Customs Authority by companies if they meet the following requirements:  Continue reading