Hungary has issued new transfer pricing documentation and reporting requirements under Decree No. 45/2025 (XII. 23.) NGM, introducing revised thresholds, reporting obligations and documentation standards for corporate taxpayers from the 2026 tax year, with limited optional application for certain local file rules in 2025.
Hungary has introduced a revised transfer pricing (TP) documentation framework through Decree No. 45/2025 (XII. 23.) NGM on 9 July 2026, accompanied by guidance from the Ministry of Finance, setting out new documentation and data reporting requirements for tax years beginning in 2026.
The new framework aligns Hungary’s TP documentation regime with the OECD’s three-tiered approach and updates documentation thresholds, reporting obligations and administrative requirements. Certain provisions relating to the local file may also be applied voluntarily for the 2025 tax year.
Scope of affected taxpayers
The documentation and data reporting requirements apply to corporate taxpayers that do not qualify as small or micro-enterprises at the end of the tax year.
The rules cover economic associations, including Kft., Bt., Zrt., Nyrt., cooperatives and European companies, foreign entrepreneurs operating through branches, and members of corporate tax groups for transactions with related parties outside the group.
Non-profit organisations and entities in which the state holds a direct or indirect majority influence remain exempt from the obligations.
Documentation thresholds revised
The Decree introduces updated monetary thresholds for transfer pricing documentation.
A Master File is required only where the total arm’s length value of related-party transactions subject to local file requirements exceeds HUF 500 million, excluding VAT, during the tax year.
Individual transactions are generally exempt from Local File preparation and TP data reporting if their arm’s length value does not exceed HUF 150 million, excluding VAT.
Cost recharge transactions are exempt from Local File preparation where their value does not exceed HUF 500 million, although they must still be included in TP data reporting.
OECD documentation structure retained
The revised framework continues to follow the OECD’s three-tiered documentation model comprising the Country-by-Country Report (CbCR), Master File and Local File.
The Master File must provide an overview of the multinational group, including its organisational structure, business operations, supply chains, intangible assets and intercompany financing activities.
The Local File focuses on individual related-party transactions and requires detailed transaction descriptions, functional analysis covering functions, assets and risks, and a comparability analysis based on the OECD’s five comparability factors.
The guidance also retains the utility test for intra-group services, requiring taxpayers to demonstrate that services received provided economic or commercial value to the recipient’s business.
A simplified Local File remains available for certain categories of transactions, including low value-added services, free cash transfers and specified cost recharge arrangements.
Rules for low value-added services
The Decree adopts the OECD definition of low value-added services (LVAS).
Under a safe harbour provision, the tax authority accepts a 5% net profit markup for both services provided and services received without requiring additional justification.
The simplified treatment does not apply to services forming part of a group’s core business, services involving unique and valuable intangibles, or activities involving significant risks.
Benchmarking and transaction aggregation
The new rules clarify when related-party transactions may be aggregated for documentation purposes, limiting aggregation to transactions that are highly interrelated or continuous. Incoming and outgoing transactions generally cannot be combined.
For benchmarking under the Transactional Net Margin Method (TNMM), the Decree specifies database search criteria, including the use of NACE/TEÁOR industry classifications and geographic filters that prioritise Hungarian comparables where the tested party is domestic.
Companies reporting losses for more than half of the analysed period or for two consecutive years are generally excluded from benchmarking datasets.
Reporting and administrative requirements
Transfer pricing documentation may be prepared in Hungarian, English or German.
Taxpayers must retain documentation for at least eight years, or for eight years following the final disposal of a related invested asset where applicable.
The Decree also requires taxpayers to submit transfer pricing data as part of their annual corporate tax return. Required information includes transaction type codes, transaction values, transfer pricing methods and profit level indicators using designated reporting forms, including ATP-01.
Transfer pricing documentation must be completed by the deadline for filing the annual corporate tax return.
