Hungary updated its transfer pricing documentation rules in line with OECD guidelines. From tax years starting in 2025, companies must prepare a local file if arm’s length related-party transactions exceed 150 million forints in a year, excluding VAT. A master file is required where the total value of such transactions goes beyond 500 million forints. The decree also allows simplified local documentation for low-value added services, provided certain conditions are met. The new rules formally enter into force on January 23, 2026.
To read more on the updated rules, click here.
Hungary has launched a consultation for its transfer pricing documentation rules. The proposal, released by the Ministry of National Economy, would replace the current 2017 decree and apply for the first time to documentation for the 2026 tax year. The aim is to clarify information requirements while reducing administrative burdens for smaller transactions. Under the draft, companies would not need to prepare a Master File if their related-party transactions total no more than HUF 500 million a year. The exemption threshold for preparing a Local File would rise from HUF 100 million to HUF 150 million, and simplified documentation rules would apply to low-value added services. Public comments are open until December 10, 2025.
The proposal can be accessed here.
Hungary’s parliament has passed two bills introducing broad tax updates and new reporting obligations. The legislation revises the country’s global minimum tax rules, extending the transitional country-by-country reporting safe harbor and clarifying which financial statements and reports are accepted for calculating the 15% minimum tax. It also implements EU reporting rules (DAC9) for the global minimum tax and EU transparency rules (DAC8) that require crypto-asset service providers to report customer information.
Another change removes the two-year limit for individuals to offset losses from cryptocurrency transactions. Parliament also maintained the suspension of the advertising turnover tax until mid-2026 and approved tax cuts worth up to HUF 90 billion to support small and medium-sized businesses.
Hungary’s parliament has passed an autumn tax package introducing significant changes to tax and compliance rules. The package gives tax authorities 60 days to review companies’ transfer pricing documentation, with extra time allowed for completing unilateral advance pricing agreements. Transfer pricing rules ensure transactions between related entities are priced as if they occurred between independent parties, preventing profit shifting to low-tax jurisdictions. The legislation also amends Hungary’s global minimum tax rules, requiring large multinational companies to pay at least 15% on global incomes, aligning with OECD guidelines. Additionally, a special per-passenger airline tax will be repealed from January 1, 2025, while retail sales tax will extend to online marketplaces. The package, passed by 114 votes to 42 with 8 abstentions, now awaits final approval from the speaker and president before becoming law.