Hungary has recently enacted a new transfer pricing regulation that will apply from 2026, with optional early adoption for 2025. The reform updates documentation obligations, introduces relief for smaller entities, and imposes stricter requirements on larger multinational groups.
Key highlights include:
An increase in transfer pricing documentation and reporting thresholds to HUF 150 million, reducing compliance burdens for lower-value related party transactions.
A Master File exemption for groups whose related party transactions do not exceed HUF 500 million annually, easing requirements for smaller and mid-sized businesses.
Stricter rules for larger taxpayers, including mandatory segmented profit analyses, stronger methodological expectations, and greater audit transparency.
Further alignment with OECD standards, including enhanced requirements relating to economically relevant characteristics and the benefits test for services.
Revised criteria for simplified documentation for low-value-adding services and certain cost allocations.
Tax experts from our Hungarian member firm LeitnerLeitner have published a detailed analysis of the practical implications which can be read here.
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