As of April
2018 Ágnes Fotiadi joined LeitnerLeitner as the leader of the newly established
transfer pricing business line. She has so far headed the Transfer Pricing Unit
of the Hungarian Tax and Customs Administration from its establishment. Due to her
work, the field has become an internationally recognized area within the
Hungarian Tax Authority.
Ágnes Fotiadi was responsible in the Hungarian Tax Authority for
evaluating and analysing data of multinational enterprises, database studies,
income calculations, controlling and preparing transfer pricing documentation,
benchmark studies and methodologies. She has appraised the Advance Pricing
Arrangements (APAs) with country-wide competence, has conducted negotiations in
Mutual Agreement Procedures (MAPs) on transfer pricing, and lead the Hungarian delegations
in such cross-border co-operations. She was an active participant in the work
of a number of international organizations such as the WP6 Working Party of the
OECD and the European Union's Committee for Taxation. She dealt with the
transfer pricing of multinational companies in these bodies.
LeitnerLeitner’s
Transfer Pricing Business Unit offers the following services
- preparation and review of transfer pricing documentation
- preparation or localization of the new types of three-tier documentation
- country-by-country reports
- master files
- country files
- APA: preparation of Advanced Pricing Agreement requests and representation during the whole procedure
- MAP: representation of multinational enterprises in the cross-border negotiations for Mutual Agreement Procedures
- assistance in transfer pricing audits, providing remedies (comments, appeals against Tax Authority challenges)
- transfer pricing expert activity: designing the transfer pricing structure within a company group, creating and introduction of transfer pricing
- policies, and providing additional transfer pricing advisory.
As reflected by all the above, LeitnerLeitner pays special attention to the
increasingly complex transfer pricing obligations, as concluding from the BEPS
project the OECD Transfer Pricing Guidelines further tightened these. With its
complex service package, LeitnerLeitner aims to help the companies affiliated
in Hungary and internationally to succeed in meeting the new challenges: create
immeasurable transfer pricing records, leverage value-based, functional and
risk analyses, support profitability calculations, which can contribute also to
reach a more economical and rational operation. LeitnerLeitner's transfer pricing
business line supports its Clients with database studies, benchmark analyses to
seamlessly adopt the new three-tier transfer pricing documentation requirements
from 2018.
