Exit tax and transfer pricing

Abstract

The article investigates the relationship between tax base amendments necessary due to either exit tax or transfer pricing rules. The main research question is whether there is any overlap between the transactions covered by exit tax or transfer pricing rules and, if affirmative, which rule has priority. The applicability of OECD recommendations, and their place in respect of EU legislation is also analyzed. In the article Hungary is used as an example of the introduction of the EU exit tax rules and their interaction with transfer pricing in the domestic legislation.