On 22 June 2022, the Hungarian finance minister submitted the 2023 Budget Bill in parliament providing following tax measures related to transfer pricing changes.

The bill proposes to revise the regulation of the application of the interquartile range. According to the amendment, the interquartile range is to be applied when applying transfer pricing methods by considering data on comparable products, services or companies that are stored in a publicly available database or tax authority verifiable database or are available from another source publicly available or from are verifiable by the tax authority.

The bill also proposes to introduce a new transfer pricing obligation. Taxpayers who are subject to submit transfer pricing information will also be required to provide related party transaction’s details in their corporate tax return. The precise content of the information to be provided would be specified in the Transfer Pricing Regulation.

The bill also proposes to change the rules on arm’s length pricing. On this basis, the transfer price does not need to be adjusted if the applied price is within the arm’s length price range and can be considered an arm’s length price. If the price applied is outside the arm’s length price range, the median is to be regarded as the arm’s length price and the transfer price is to be adjusted to this point. An exception is when the taxpayer demonstrates that a value other than the median within the range best fits the transaction under consideration, then it should be adjusted to that value instead of the median.