Kondor – TP

Transfer pricing on a supreme level

Table of Content

Transfer price consulting

Our team of advisors has been engaged in the preparation of transfer pricing documents since the introduction of the Hungarian legislation.

At Kondor-TP, the Transfer Pricing Expert Group works closely with staff working in the international and domestic tax field, enabling to deal with the complexity of the impact of intra-group transactions within different tax aspects. Thus, we can provide assistance not only in the planning of transfer prices but also in the complex tax evaluation of already completed transactions.

Our consultants followed numerous tax authority procedures, have up-to-date knowledge of tax administration practices and tax law changes.

Transfer pricing services

Preparing transfer pricing documentation

Benchmark analysis with database screening

Masterfile – Preparation of group level TP documentation

Preparation of transfer pricing policy

Transfer pricing education

Preparation of APA request

Legal representation in front of the Tax Authority

TP Health check

Unique TP documentation – in accordance with the legal regulations and expectations of the authorities

Kondor-TP places emphasis on the consistency of the method used for the establishment of the arm’s length price and the expectations of the Tax Authority and the Ministry of Finance.

Preparing a transfer pricing documentation requires complex and unique effort, since contrary to other internal regulations (for example accounting policy) in the case of transfer prices, there is no such sample documentation that can be used for all the companies with little corrections.

The Tax Authority may levy significant penalties if the transfer prices applied between the related companies do not correspond to the prices applied between independent parties in the same circumstances. That is why it is important to have experienced advisors assist You, and that the precise and exhaustive work we provide to serve as a reassuring and safe background to the business operations of your company.

Why is it advisable to work with an experienced and competent transfer pricing expert?
The steps of the preparation transfer pricing documents:

Commitment and quality guarantee

Since the introduction of the transfer pricing legislation in 2003, the Tax Authority pays special attention in its audits to transfer prices and related parties. If the parties did not apply appropriate prices in the transactions among each other, the Authority may impose serious penalty on them.

In order to avoid the abovementioned scenario, it is the task of KONDOR-TP to provide assistance and advice tailored to Your needs as possible. We are aware that in this field, every mistake may have severe consequences, so we work with colleagues who gained their transfer pricing experience at the Tax Authority and/or at the largest international tax advisor companies. Besides the knowledge of international best practices, they also know the specificities of the revision procedures of the local Tax Authority. Full commitment and experience mean quality guarantee..

In every case we adapt our services to the requirements of the Client. As part of our advisory services our advisors examine the transactions between the related parties or the transfer pricing documentations that are already prepared by the Group, and they also provide a summary of their expert opinion on them.

If required, we help our clients to prepare the whole transfer pricing documentation or specific parts of it (for example choosing the appropriate method or preparing benchmark analysis). We also can assist in drawing up APA requests or requests for resolution of the Authority in specific issues. Our objective is to defend the pricing practices of our clients during a tax revision, so to avoid transfer pricing penalties and even the administrative burden of a complex tax audit.

Transfer pricing in general

Usual market prices are applied in transactions between independent parties in accordance with the market conditions. However it is possible that the contracting parties are not independent, but are related parties. Companies are deemed to be related parties if the owners are the same, one company is the majority owner of the other one, or the domestic company has a foreign parent company, etc. – but other factors can result in related party relationship according to the definition of the Act on Corporate Income Tax.

In the case of related parties, the prices applied in the transactions between the parties are called transfer prices. Transfer prices can affect the profits of the companies involved and the amount of tax due. In Hungary, the obligation to prepare transfer pricing documentations was introduced in 2003, and since then prices applied between related parties are a matter of priority in the audit policy of the Tax Authority. Companies having related party transactions shall have a specific transfer pricing documentation on the prices applied if the transaction value is above a certain threshold.

Szarvady Zsófia Irodavezető
Head of Back Office

Zsófia Szarvady

Zsófia Szarvady graduated as an economist in 2012 at the Budapest Business School with a bachelor’s degree and in 2015 at the Budapest Metropolitan University with a master’s degree. During her studies and the following years she gained extensive experience in the Front Office department of InterContinental Budapest. In 2016 she joined PwC Hungary, where she strengthened the support team as team assistant, personal assistant and financial assistant. She joined KONDOR Group in February 2019 as an office manager and currently holds the position of Head of Back office.

Head of OD and HR, Partner

Lili Polgár

Lili Polgár is HR Business Partner economist (summa cum laude), internationally accredited Human Synergistics consultant in leadership development, organisation developer. She has 20 years of experience in organization and leadership development from the SME sector through state-owned companies to multinational companies. As a consultant, she focuses on developing executives, creates and coordinates change management processes and supports leaders to cooperate and teamwork. Co-founder of KONDOR OD, Partner of KONDOR Group since 2019.
Puskás Zsuzsanna Könyvelés és bérszámfejtés üzletágvezető
Head of Accounting and payroll

Zsuzsanna Puskás

Zsuzsanna Puskás obtained the qualification of a certified public accountant in 2000 after graduating as a business administrator and a small business economist. She then continued her studies at Szent István University, majoring in economics. After gaining nearly ten years of accounting and taxation experience, she worked as an accounting team leader at one of the ten largest Hungarian accounting service providers, and at the same time she worked on the development and operation of the quality management system. She started his own accounting services company in 2011 and then joined the KONDOR Group in 2018 as the head of the accounting business.

Tax Leader

József Vizer

József Vizer graduated in 2003 as an economist at the Budapest Business School, Faculty of Finance and Accountancy. He qualified as a chartered accountant in 2003, as a tax advisor in 2006 and as a chartered tax specialist in the field of value added tax and international taxation in 2012. After having gained nearly ten years of experience in the field of tax administration and tax advisory, since 2013 he worked in various leadership positions at Lidl Hungary and then at RSM Hungary. He joined KONDOR Group in 2020 as the Head of Tax Advisory.

Pásztor László 2005-ben végzett közgazdászként a Pécsi Tudományegyetemen, adótanácsadói bizonyítványát 2007- ben szerezte meg. 2011-ben a közvetlen adók területén nemzetközi adószakértő címet nyert el. Több, mint egy évtizede foglalkozik nemzetközi adózással és transzferárazási kérdésekkel. A TranszFAIRár című könyv társszerzője, a TP GROUP társalapítója, szakmai vezetője. 2017-től a KONDOR Csoport Partnere.
Tax expert, Head of TP and Financial Advisory, Partner

László Pásztor

László Pásztor graduated as an economist at the University of Pécs in 2005 and obtained his tax advisor certificate in 2007. In 2011, he earned the international tax expert title in the field of direct taxes. He has been dealing with international taxation and transfer pricing issues for more than a decade. He is co-author of the book, TranszFAIRár, co-founder of TP GROUP, and Head of TP at KONDOR-TP. From 2017, he is a Partner of KONDOR Group.

Kondor Bence Barnabás 2002-ben végzett jogászként. A PhD képzéssel párhuzamosan kezdte meg tanulmányait a Budapesti Corvinus Egyetem Gazdálkodástudományi Karán (2002-2007). 2008 óta foglalkozik transzferárazással, valamint vállalkozás- és üzletfejlesztéssel. A TranszFAIRár című könyv társszerzője. A TP GROUP a KONDOR Csoport és a VISEGRAD Consulting Group alapítója.
Founder, Partner

Bence Barnabás Dr. Kondor

Bence Barnabás Dr. Kondor graduated in 2002 as a lawyer. In parallel with his PhD studies, he began his Business Administration studies at Corvinus University of Budapest (2002-2007). Since 2008, he has been dealing with transfer pricing and business development. He is co-author of the TranszFAIRár Book. He is the founder of TP GROUP, KONDOR Group and VISEGRAD Consulting Group.

Bársony Farkas pénzügyi jogász, hosszú ideig a GE Hungary ügyvezető igazgatója és több GE üzletág globális és EMEA adóügyi igazgatója. Legutóbb a PwC CEE TLS Partnere. Az Amerikai Kereskedelmi Kamara (AmCham Hungary) elnöke. Munkája elismeréseként a Magyar Érdemrend Lovagkereszt kitüntetettje. A Nemzeti Versenyképességi Tanács tagja. A VISEGRAD Consulting Group társalapítója, 2019-től a KONDOR Csoport Partnere.
CEO, Partner

Farkas Dr. Bársony

Farkas Dr. Bársony is a finance lawyer (LL.M., MBA), was the managing director of GE Hungary and the (EMEA & Global) tax director of several GE businesses. Following that he was appointed as Tax and Legal Services Partner at PwC CEE. He was the President of the American Chamber of Commerce (AmCham Hungary) between 2016 and 2020. In recognition of his professional work, he was awarded the Knight’s Cross of the Order of Merit of the Republic of Hungary. He is a member of the National Competitiveness Council. Co-founder of VISEGRAD Consulting Group, and currently the CEO & Partner of KONDOR Group since 2019.