The National Tax and Customs Administration (NTCA) approach in transfer pricing matters tends to be conservative; in practice it requires the application of statistical methods (specifically, the use of the interquartile range) to narrow the final range of comparable values. In a recent case, however, such approach was successfully challenged by a taxpayer. This taxpayer (the "Company") is a Hungarian tax resident manufacturer. It acquires the required raw material partly from related parties and it also sells the final products partly to related parties. In accordance with the Hungarian transfer pricing regulation, it prepared transfer pricing documentation determining the arm's...