The regulation requires taxpayers to produce a multi-entity Master File and a transaction-specific Local File, though various monetary thresholds offer specific exemptions for smaller-value transactions. The consultation is set to conclude on 10 December 2025. 

RF Report

Hungary’s Ministry of National Economy announced, on 2 December 2025, that it is inviting feedback on a proposed overhaul of its transfer pricing documentation rules.

The revision aims to clarify reporting requirements, expand the information covered, and reduce administrative burdens for smaller transactions. The overhaul of the transfer pricing rules also aims to harmonise domestic tax compliance with OECD guidelines and provide tax authorities with standardised, verifiable data for efficient risk analysis and auditing related to the arm’s length principle.

The regulation requires taxpayers to produce a multi-entity Master File and a transaction-specific Local File, though various monetary thresholds offer specific exemptions for smaller-value transactions.

Extensive requirements are specified for the contents of these documents, including detailed functional analysis, characterisation of the parties involved (e.g., routine entities), and strict guidelines for conducting comparability searches and determining appropriate profitability indicators.

Furthermore, the rules mandate structured transfer pricing data reporting for over fifty categorised transaction types, detailing the financial outcome and the underlying tax adjustments.

These requirements for documentation and data submission are primarily intended to take effect in the 2026 calendar tax year.

Transfer Pricing Documentation

Taxpayers are required to prepare two primary documents annually for related party transactions based on performance that occurred in the tax year:

  1. Master File
  2. Local File (prepared per related transaction or aggregated transactions)

Exemptions from Documentation

Master File: Not required if the total countervalue of all related party transactions, calculated at the arm’s length price, does not exceed HUF 500 million in the tax year.

Local File: Not required for a transaction if its countervalue does not exceed HUF 150 million (excluding VAT, calculated at arm’s length price).

Further Local File exemptions apply to:

  • Transactions where the Hungarian authority has determined the arm’s length price via a resolution.
  • The unchanged recharge of costs for assets or services acquired from an independent party, provided the recharge value does not exceed HUF 500 million (excluding VAT, calculated at arm’s length price).
  • Stock exchange transactions (unless related to insider trading or market manipulation).
  • Transactions involving fixed official prices or prices defined explicitly by law.
  • Transactions with private individuals (not acting as sole proprietors).

The consultation closes on 10 December 2025.