Key findings indicate a growing interest in transfer pricing matters across most CEE jurisdictions. Audit durations vary, with Romania, Hungary, and Serbia generally conducting shorter audits, while others like Czechia may extend over several years. Formal agreements to close audits are not feasible, but constructive dialogue often aids in avoiding prolonged disputes. 

Each tax authority typically relies on its resources and standards, sometimes necessitating adjustments to centrally prepared TP studies to align with local practices. In certain jurisdictions, audits are centrally coordinated, involving guidelines from central authorities particularly in complex cases. 

Advanced Pricing Agreements (APAs) are crucial for mitigating risks associated with inconsistent audit practices and lengthy dispute resolution processes, offering a means to agree on TP methodologies. Penalties are imposed for non-compliance, including criminal penalties in specific cases of tax evasion. 

Understanding these dynamics is vital for businesses to effectively navigate transfer pricing audits in the CEE region, minimize risk, and ensure compliance, thereby safeguarding their operations and financial interests.  

Explore more about these dynamics to effectively navigate transfer pricing audits and get in touch with our team to discuss how these findings may apply to your specific situation. 

How can Deloitte help?

Our multi-disciplinary team combines tax advisors and legal professionals and is ready to support you TP needs across CEE.

We can assist you with: 

• Designing and implementing transfer pricing strategies and policies aligned with applicable TP regulations, 

• Preparing TP documentation and reporting that reflect the specific requirements of each jurisdiction, 

• Reviewing TP models, policies, documentation, and contracts to bring consistency, accuracy, and compliance with TP obligations, 

• Advising on adjustments to TP models, policies, contracts, and documentation to mitigate the risks of disputes, 

• Developing an effective TP audit strategy, 

• Representing and providing support throughout tax audits, as well as during tax and court proceedings.